Miranda v. YBJ Incorporated

Background

Moises Gilberto Jimenez Miranda sued YBJ Incorporated, Yosef Hechter, Robert Berk, and Miguel Ovalles. He asserted wage-and-hour claims under the Fair Labor Standards Act and the New York Labor Law. He alleged that he worked about 51 hours per week without receiving overtime pay, was paid $11 per hour from January 2018 through December 2020 despite the New York minimum-wage requirements, and did not receive required payroll records or wage statements.

Miranda also asserted a discrimination claim under the New York State Human Rights Law. He alleged that he was ridiculed and harassed because he is gay, that supervisor Miguel Ovalles encouraged other employees to mock him, that Ovalles required him to carry heavy items alone, and that Ovalles terminated him after he requested a day away from work to receive a vaccination. The complaint mentioned the New York City Human Rights Law once but did not separately plead a claim under that law. The court therefore treated the complaint as asserting only a New York State Human Rights Law claim, while stating that any intended New York City claim would be dismissed for the same reason.

Motion and Jurisdiction

Defendants filed an unopposed motion under Federal Rule of Civil Procedure 12(b)(1), which addresses the court’s subject-matter jurisdiction. The court had original jurisdiction over the Fair Labor Standards Act claim because it arises under federal law. Because the parties were not diverse in citizenship, the court considered whether it could exercise supplemental jurisdiction over the state-law discrimination claim. Supplemental jurisdiction allows a federal court to hear related state-law claims that form part of the same constitutional case or controversy.

The court explained that claims generally share a common case or controversy when they arise from a common set of operative facts. It concluded that the wage claims concerned what Miranda was paid and how long he worked, while the discrimination claim concerned alleged mistreatment by supervisors and coworkers, protected-class discrimination, and termination. The only overlapping fact was the employment relationship. The court therefore agreed that the discrimination claim had no sufficient factual connection to the wage claims for supplemental jurisdiction.

The court also stated that it could exercise supplemental jurisdiction over the New York Labor Law claims because those claims and the Fair Labor Standards Act claims arose from the same compensation policies and practices. Defendants had not moved to dismiss the New York Labor Law claims.

Disposition

Judge Briccetti granted defendants’ partial motion to dismiss. The court dismissed Miranda’s New York State Human Rights Law discrimination claim without prejudice for lack of subject-matter jurisdiction. It instructed defendants to file an answer to the complaint by May 11, 2023, and directed the clerk to terminate the motion.