Rios v. Linn Star Transfer, Inc.
- Jacquelyn Corley
- 3:19-cv-07009
- U.S. District Court · Northern District of California
- 11
In Rios v. Linn Star Transfer, Judge Corley granted individual defendants’ dismissal motions and denied plaintiffs’ sanctions motions in wage-and-hour cases.
The individual defendants obtained dismissal of the challenged claims against them. The sections 201 and 204 claims were dismissed with prejudice as to those defendants, while the plaintiffs could amend their meal-break, expense-reimbursement, and waiting-time claims within 21 days. The court did not dismiss those wage claims against Linn Star in this order, and it denied the plaintiffs’ sanctions motions.
What happened
Rios v. Linn Star Transfer, Inc. involved current and former delivery drivers who alleged that Linn Star misclassified them as independent contractors and violated federal and California wage laws. They sued Linn Star and four individual defendants described as owners, directors, officers, or managing agents.
The individual defendants asked the court to dismiss claims involving unpaid wages, meal breaks, expense reimbursement, and waiting-time penalties. The plaintiffs argued that California Labor Code section 558.1 could make the individuals liable. The court ruled that sections 201 and 204 did not impose liability on individuals, and that the remaining allegations did not provide enough specific facts showing the individuals’ personal involvement.
Judge Jacquelyn Scott Corley granted the individual defendants’ motions to dismiss and denied the plaintiffs’ motions for sanctions. The unpaid-wage claims under sections 201 and 204 were dismissed with prejudice as to the individual defendants; the plaintiffs could amend the meal-break, expense-reimbursement, and waiting-time claims within 21 days, but could not add other claims.
The detailed version
- Rios v. Linn Star Transfer, Inc. · No. 3:19-cv-07009
- Jacquelyn Corley
- Apr. 6, 2020
Background
The three related cases concern current or former delivery drivers who worked out of Linn Star’s Benicia, California branch. The plaintiffs alleged that Linn Star Transfer, Inc. and Linn Star Logistics, LLC misclassified them as independent contractors rather than employees. They asserted claims under the California Labor Code, the Fair Labor Standards Act, and California’s unfair-competition law. The complaints also named four individual defendants: Kevin Abbey, Mark Dahlin, David Dunek, and Dennis Munson.
The individual defendants moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not allege enough facts to state a legally plausible claim. The plaintiffs separately moved for sanctions under Rule 11, arguing that the motions to dismiss were not supported by existing law or were brought for an improper purpose.
Claims Against the Individual Defendants
The individual defendants sought dismissal of unpaid-wage claims under California Labor Code sections 201 and 204, meal-period claims under sections 226.7 and 512 and the applicable wage order, expense-reimbursement claims under section 2802, and waiting-time claims under section 203 in two of the cases.
The court held that sections 201 and 204 impose liability on employers, not on individuals acting for an employer. Although the complaints invoked section 558.1, that provision lists sections 203, 226, 226.7, 1193.6, 1194, and 2802, but does not list sections 201 or 204. The court therefore concluded that the section 201 and 204 claims failed as a matter of law against the individual defendants. The plaintiffs could continue pursuing those claims against Linn Star.
The court reached a different pleading conclusion for the meal-break, expense-reimbursement, and waiting-time claims. It recognized that section 558.1 can extend liability for those types of Labor Code violations to certain owners, directors, officers, or managing agents. But the complaints alleged only that the individual defendants held those positions and violated or caused violations of the wage laws. The court found those allegations conclusory because they did not provide specific facts showing the individual defendants’ personal involvement.
Sanctions and Disposition
The court rejected the plaintiffs’ request for Rule 11 sanctions. It found that the individual defendants had valid grounds for seeking dismissal, including the argument that section 558.1 did not apply to the sections 201 and 204 claims and that the other challenged claims lacked sufficient factual allegations.
Judge Jacquelyn Scott Corley denied the plaintiffs’ motions for sanctions and granted the individual defendants’ motions to dismiss. Dismissal was with prejudice as to the Labor Code sections 201 and 204 claims against the individual defendants. The plaintiffs were permitted to file an amended complaint within 21 days concerning the meal-break, expense-reimbursement, and waiting-time claims against those defendants. The court did not grant permission to add any other claims.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.