Seaworth v. Klst, Inc.

Background

Ronald T. Seaworth sued KLST, Inc., and Kedrick Johnson, Scott Johnson, Todd Johnson, Danyell Wendland, Ross Ristinen, and Amy Klemz. The opinion states that Seaworth was a former employee of KLST, Inc., which does business as ABRA Auto Body and Glass, and that the individual defendants were employees of or otherwise affiliated with ABRA.

Seaworth alleged 18 counts of “wage theft/embezzlement” and one count of retaliation for reporting the alleged wage theft to his employer. He cited Minnesota statutes concerning theft and retaliation, “Federal wage laws,” 42 U.S.C. § 12203, 18 U.S.C. § 3571, and the “Fair Wage act” as possible bases for federal-question jurisdiction.

Jurisdictional analysis

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), arguing that the court lacked federal subject-matter jurisdiction. The court explained that federal-question jurisdiction generally requires a claim created by federal law or a state-law claim that necessarily raises a substantial and disputed federal issue.

The court rejected each asserted federal basis:

- 42 U.S.C. § 12203: This provision is the Americans with Disabilities Act’s anti-retaliation provision. The court found that Seaworth’s complaint contained no allegations about a disability or another status protected by the Act. It therefore concluded that Seaworth had not pleaded an Americans with Disabilities Act claim and that § 12203 could not provide jurisdiction. - 18 U.S.C. § 3571: The court explained that this is a criminal statute setting out fines that may be imposed after a federal offense has been established. Because the statute did not provide a civil cause of action for Seaworth’s alleged embezzlement claims, it could not support federal jurisdiction. - “Fair Wage act”: The court found that Seaworth did not identify an enacted federal law by that name. The court stated that an unenacted bill cannot provide federal-question jurisdiction. - Significant federal issue: The court found that Seaworth had not shown that his Minnesota-law claims necessarily raised a substantial, disputed federal question. Based on the complaint, Minnesota wage-theft and retaliation laws appeared to form the basis of his claims.

The court’s footnote also addressed Seaworth’s reference in his response to “42 USC Title VI.” The court stated that Title VI was not cited in the complaint and that Seaworth had not alleged discrimination based on race, color, or national origin, or that the defendants operated a program or activity receiving federal financial assistance. The court concluded that Title VI could not confer jurisdiction.

Disposition

The court granted the defendants’ motion to dismiss and dismissed the case without prejudice. The clerk was directed to terminate Seaworth’s motion to deny the defendants’ motion to dismiss. The opinion does not state whether any amended complaint was filed or whether the claims were pursued elsewhere.