Mateer v. Peloton Interactive, Inc.

Background

Peloton moved to dismiss two claims in the First Amended Complaint. It sought dismissal of Plaintiff Johnson’s claim under Pennsylvania’s Wage Payment and Collection Law (WPCL) under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. Peloton also challenged Plaintiff Mateer’s claim under New York’s Wage Theft Prevention Act (WTPA) for lack of standing, meaning lack of a sufficient injury to invoke the federal court’s authority.

Johnson’s WPCL Claim

The court denied Peloton’s motion to dismiss Johnson’s WPCL claim. The court explained that the WPCL provides a remedy when an employer breaches a contractual obligation to pay earned wages; it does not independently create a right to compensation. The First Amended Complaint alleged that a letter agreement, together with policy documents and other agreements incorporated by reference, created a contractual obligation to pay Johnson overtime wages. Although the letter itself did not appear to guarantee overtime pay, the court was required at the motion-to-dismiss stage to accept the well-pleaded allegations as true. The court therefore found that the complaint sufficiently stated a WPCL claim.

The court noted that the First Amended Complaint did not allege that a later agreement superseded the letter agreement. If Plaintiffs intended to rely on a later agreement, the court directed them to amend the complaint to say so.

Mateer’s WTPA Claim

The court also denied Peloton’s motion to dismiss Mateer’s WTPA claim for lack of standing. The court found that the allegations went beyond a merely technical violation of the statute. The First Amended Complaint alleged that Peloton’s violation resulted in underpayment of wages, and the court held that monetary injury is a concrete harm sufficient to establish standing.

Peloton argued that the alleged underpayment resulted from timekeeping practices and the alleged misclassification of employees, rather than from the WTPA violation. The court nevertheless concluded, viewing reasonable inferences in Mateer’s favor, that the complaint sufficiently alleged that the WTPA violation also contributed to the underpayment.

Orders and Deadlines

The court ordered Plaintiffs to state by July 21, 2022, whether they intended to amend the First Amended Complaint and to file any amended complaint by July 28, 2022. The court ordered Peloton to answer the operative complaint by August 4, 2022. Judge Lorna G. Schofield denied both motions to dismiss; the order did not resolve the ultimate merits of either wage claim.