Morgan v. Signant Health Global LLC

Background

Signant provides information technology and support services for clinical trials. Nicholas Morgan worked for Signant, participated in the Signant Health Incentive Compensation Plan, and alleged that he was not paid all commissions due. He later became Director of Business Development and left Signant’s employment on November 6, 2024.

Morgan’s first amended complaint sought to represent three classes of current and former employees. The motion concerned the proposed “Failure to Pay Commission Wages Class,” consisting of participants in the plan effective April 1, 2024, who were not paid all commission wages due.

Motion and legal standard

Signant moved to dismiss or, alternatively, to strike allegations concerning unpaid commissions and the related class allegations. The court chose to decide the motion under Federal Rule of Civil Procedure 12(f), which allows a court to remove from a pleading material that is immaterial, impertinent, redundant, or otherwise improper. The court noted that motions to strike are generally disfavored but found this motion to be an efficient way to address the allegations at issue.

Court’s analysis

The plan stated that a participant “must remain continuously employed” through the date of the incentive payment. The court found that Morgan was not employed on the payment date. It therefore concluded that Morgan could avoid the plan’s express condition only by plausibly alleging that the provision denying commissions was unconscionable, meaning unfairly imposed or unfair in its terms.

The court found that the first amended complaint did not address procedural unconscionability, which concerns unfairness in how an agreement or provision was presented or adopted. It held that the unpaid-commission allegations were therefore immaterial under Rule 12(f).

The court granted the motion to strike those allegations. It left intact references to the number of proposed classes and the seventh cause of action’s references to the commissions classes. The court also stated that the motion left the other two proposed classes undisturbed.

Disposition

Judge Row A. Westmore granted Signant’s alternative motion to strike and gave Morgan leave to amend. The court specifically struck allegations concerning the right to unpaid incentive payments or unpaid commissions in paragraph 21, paragraph 23(c), paragraph 26(b), part of paragraph 26(u), and paragraphs 43 through 50 of the first amended complaint.

Morgan may file a second amended complaint within 21 days. The court stated that all causes of action survive without the stricken allegations. If Morgan does not amend, Signant must answer the first amended complaint 14 days later. The initial case-management conference was continued to March 24, 2026, and the court did not separately state a disposition of the dismissal request apart from granting the alternative motion to strike.