Scott v. Cintas Corporation

Background

Isaiah Scott, identified as a former Management Trainee at Cintas Corporation, alleged that Cintas violated the Fair Labor Standards Act (FLSA), a federal wage-and-hour law, and several California Labor Code provisions. He alleged that he worked in California from approximately October 2020 through approximately January 2022, regularly working nine to ten or more hours per day and 45 to 55 or more hours per week.

Scott alleged that Cintas classified him and other Management Trainees as exempt from overtime requirements and did not pay overtime for work exceeding eight hours in a day or 40 hours in a week. He also alleged that Cintas lacked policies or practices providing meal and rest periods to California Management Trainees. His second amended complaint asserted eight causes of action: FLSA overtime, California overtime, meal-break violations, rest-break violations, inaccurate wage statements, untimely payment of wages, waiting-time penalties after termination, and violations of California’s Unfair Competition Law. Scott sought to represent a proposed nationwide FLSA collective action and a California class.

Motion Concerning Non-California Workers

Cintas moved under Federal Rule of Civil Procedure 12(b)(2), which concerns personal jurisdiction, and Rule 12(f), which permits a court to strike certain material from a pleading, to dismiss or strike claims asserted on behalf of non-California workers.

The court held that this request was premature. At that point, Scott was the only plaintiff, and he had worked for Cintas only in California. Under the FLSA, workers become parties to a collective action by filing written consent forms to join it. Because no non-California workers had opted in, the court declined to address Cintas’s personal-jurisdiction argument as to those hypothetical future plaintiffs. In the conclusion, the court denied the motion to strike without prejudice.

Rule 12(b)(6) Motion

Cintas also moved under Rule 12(b)(6), which tests whether a complaint alleges enough facts to state a legally viable claim.

Overtime Claims

The court granted the motion to dismiss the FLSA and California overtime claims. Scott identified one week—the week of December 7, 2020—in which he allegedly worked approximately 55 hours, but the court found that he did not plead enough additional facts to make it plausible that he had not been paid overtime. The complaint did not allege his average pay rate, the amount of overtime wages he believed he was owed, or other facts supporting that inference. The court dismissed both overtime claims with leave to amend.

Meal and Rest Break Claims

The court granted the motion to dismiss the meal- and rest-break claims with leave to amend. Scott alleged that Cintas had no policy or practice of providing those breaks, but he did not allege a specific occasion when he personally missed a break or was prevented from taking one. The court found that the alleged lack of a policy, without facts showing how it affected Scott, was insufficient.

Wage Statements

The court dismissed the inaccurate-wage-statement claim with leave to amend. Scott treated that claim as dependent on the alleged overtime and meal- and rest-break violations. Because the court found those underlying claims insufficiently pleaded, it also found the derivative wage-statement claim insufficiently pleaded.

Untimely Payment of Wages

The court granted the motion to dismiss the claim for untimely payment of wages and dismissed it with leave to amend. Scott did not allege that Cintas failed to pay him on the twice-monthly schedule required by the California Labor Code. The court also noted that a claim based only on underpaid wages does not establish a violation of the statute governing payment timing.

Waiting-Time Penalties

Scott alleged that Cintas failed to pay all wages due when his employment ended. The court found that the complaint plausibly suggested that he either was discharged or quit, but it did not identify which occurred. The court stated that Scott could pursue a claim based on either discharge or quitting, but not both. The conclusion states that Cintas’s motion to dismiss was granted as to all claims, and the dismissed claims were given leave to amend.

Unfair-Competition Claim

The court found the California Unfair Competition Law claim insufficiently pleaded because it was based on the other alleged labor-law violations, which the court also found insufficiently pleaded. The court therefore dismissed the claim with leave to amend as part of its ruling granting Cintas’s motion to dismiss all claims.

Disposition

The court granted Cintas’s motion to dismiss as to all claims, with leave to amend. The court denied Cintas’s motion to strike without prejudice. Any amended complaint was due by April 26, 2024. The court also continued the initial case-management conference to May 30, 2024, and stated that the order disposed of Docket No. 22.