Modad v. Santa Clara Valley Transportation Authority

Background

Amin Modad alleged that the Santa Clara Valley Transportation Authority denied him and a proposed class of employees meal breaks every day. He alleged that the Authority deducted 30 minutes of pay for each shift, leading to claims under the Fair Labor Standards Act (FLSA) and California Labor Code section 1194. The operative pleading was Modad’s first amended complaint, or FAC.

The FAC was unclear about the period covered by the claims. It referred to violations during the entirety of Modad’s approximately 22 years of employment, while the proposed class definition referred to employees working for the Authority within the previous three years.

Court’s Analysis

The Authority moved to dismiss the FAC for failure to state a claim. The court applied the federal pleading rule requiring a complaint to contain enough factual detail to make entitlement to relief plausible.

The court relied on Ninth Circuit authority stating that a wage claimant may establish plausibility by providing information such as the average length of the workweek, the average pay rate, the amount of overtime allegedly owed, or other facts showing that the employer likely violated wage laws. The court stated that this approach also applies to meal-break claims.

The court found Modad’s allegations insufficient because he did not identify a single specific week during his approximately 22 years of employment when he was denied a meal break and consequently was owed overtime or minimum wages. The court also noted that the FAC did not explain Modad’s wages during the entire period, whether he complained about missed meal periods, whether the alleged policy remained consistent throughout his employment, or whether the claims were timely under the applicable limitations periods.

The court stated that even if Modad intended to limit the claims to three years, he still needed to add facts about his own missed breaks. The court contrasted the FAC with a complaint that described the work conditions causing the plaintiff to miss breaks and identified specific facts about those conditions. The court concluded that Modad’s general allegations about the Authority’s policy and practice did not provide enough detail to put the Authority fairly on notice of the claims.

The California Labor Code section 1194 claim was also deficient because, according to the opinion, it rose and fell with the federal wage claim.

Disposition

The court granted the Authority’s motion to dismiss the FAC with leave to amend. Modad was granted leave to file an amended complaint by September 24, 2026. He may not add claims or parties without the Authority’s consent or the court’s permission. The Authority must respond within 14 days after the amended complaint is filed. The opinion text does not identify the magistrate judge by a legible name.