White v. Iris Nova Ltd.
- John Cronan
- 1:22-cv-08062
- U.S. District Court · Southern District of New York
- 2
In White v. Iris Nova, Judge Cronan ordered White to state whether she will continue wage-information claims before a default-judgment hearing.
Alonia White and the defendants, including Iris Nova Ltd., were affected by the order concerning the continuation of the wage-information claims and the timing of the default-judgment hearing.
What happened
In White v. Iris Nova Ltd., Alonia White asserted that the defendants violated New York labor law by failing to provide required wage notices and wage statements. She sought damages and had a pending request for default judgment against the defendants.
The court noted that courts in the Southern District of New York had found that failing to provide wage information, without more, was not enough to establish an injury required for federal-court standing. The court ordered White to tell it by June 12, 2023, at 1:00 p.m., whether she intended to continue pursuing those claims.
If White continued the claims, the court said it would adjourn the default-judgment hearing and request additional briefing; if she did not, she could inform the court that she no longer intended to pursue them. Judge John P. Cronan did not decide the default-judgment request in this order.
The detailed version
- White v. Iris Nova Ltd. · No. 1:22-cv-08062
- John Cronan
- June 9, 2023
Background
On April 27, 2023, the Court ordered the defendants to appear and show cause at a June 12, 2023 hearing why default judgment should not be entered against them. Default judgment is a judgment entered against a party that has failed to defend the case.
White's Seventh and Eighth Causes of Action alleged that the defendants violated New York Labor Law §§ 195(1) and 195(3) by failing to provide wage notices and wage statements. She sought damages for those alleged violations.
Court's Analysis
The Court noted that several courts in the Southern District of New York had held that the failure to provide wage-related information, without more, was insufficient to allege an injury in fact. An injury in fact is a concrete harm required for standing—the plaintiff's legal ability to bring a claim in federal court.
The Court did not decide whether White had standing, whether the defendants were liable, or whether default judgment should be entered. Instead, it required White to state whether she intended to continue with the Seventh and Eighth Causes of Action.
Order and Effect
The Court ordered White to notify it by June 12, 2023, at 1:00 p.m., whether she intended to proceed with those claims. If she continued them, the Court would adjourn the default-judgment hearing and request further briefing. If she no longer intended to pursue them, she was to inform the Court. The order did not grant or deny default judgment and did not state that the claims were dismissed.
The order is a procedural order because it addressed a threshold standing issue and set the next step in the case without deciding the underlying wage-law claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.