Maldonado Juarez v. Butterfield Catering Inc.

Background

Miguel Angel Maldonado Juarez sued Butterfield Catering Inc., doing business as Butterfield Kitchen, and individual defendants under the Fair Labor Standards Act (FLSA) and the New York Labor Law. The defendants moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal for failure to state a legally sufficient claim. Maldonado Juarez separately moved to strike the defendants’ reply brief and sought sanctions.

Claims Against Butterfield Catering

The court held that the amended complaint adequately pleaded an FLSA overtime claim against Butterfield Catering. Maldonado Juarez alleged that he worked as a cook, worked approximately 50 hours per week from October 2018 through December 2019, worked approximately 98 hours per week during one month, and worked approximately 59 hours per week on five other occasions. He also alleged that he was paid $15 per hour for up to 40 hours and $18 per hour for hours above 40.

The court concluded that these allegations sufficiently described work exceeding 40 hours in particular workweeks and unpaid or inadequately paid overtime. It also found sufficient allegations supporting FLSA coverage, including the company’s alleged annual sales of at least $500,000 and the alleged use and handling of goods produced outside New York.

The defendants argued that Maldonado Juarez had never been employed by Butterfield Catering and that the company’s employees did not handle goods or materials moved in interstate commerce. The court treated those arguments as factual disputes that could not be resolved on a motion to dismiss. The motion to dismiss the FLSA and New York Labor Law claims against Butterfield Catering was denied.

Claims Against Individual Defendants

The court held that Maldonado Juarez did not plead enough facts to show that the individual defendants were employers under the FLSA or New York Labor Law. The complaint generally alleged that they controlled the company, wages, hiring, and firing, but it provided few supporting facts. It alleged that two individual defendants came to the café and gave orders, and that one allegedly ordered Maldonado Juarez’s termination. It did not provide sufficient factual detail showing that the individual defendants controlled work schedules or employment conditions, set pay, maintained employment records, or otherwise exercised the required operational control.

The court rejected the argument that control could simply be inferred because the business was small. It granted the motion to dismiss the claims against the individual defendants and dismissed those claims without prejudice. The court allowed Maldonado Juarez 45 days from November 24, 2020, to file an amended complaint limited to additional allegations concerning the individual defendants.

Other Motion and Disposition

The court denied Maldonado Juarez’s motion to strike and for sanctions. The court also stated that, because it sustained the FLSA claim against Butterfield Catering, it did not address the defendants’ argument that the New York claims should be dismissed for lack of supplemental jurisdiction.

Judge Lewis J. Liman therefore denied the motion to dismiss the claims against Butterfield Catering, granted the motion to dismiss the claims against the individual defendants, dismissed those individual claims without prejudice, and denied the motion to strike and for sanctions.