BLAKLEY v. CELADON GROUP, INC.
1:16-cv-00351
S.D. Ind.Aug 14, 2017Background
- Plaintiffs (commercial truck drivers) entered Contractor Operating Agreements with Celadon that allowed Celadon to withhold/set off compensation for advances and operating costs, and required escrow accounts to secure indebtedness.
- Plaintiffs routinely received cash or fuel-card advances from Celadon (with one-time service fees) that were repaid by deductions from trip paychecks or from escrow on termination.
- Plaintiffs sued alleging advances and deductions violated Indiana consumer loan statutes and wage statutes, including claims under Section 2 of the Indiana Wage Assignment Act and the Indiana Wage Deduction Act.
- The Court previously dismissed the consumer-loan claims and Section 3 of the Assignment Act, then asked the parties to brief whether private rights of action exist under Section 2 and the Deduction Act and whether plaintiffs suffered damages.
- Plaintiffs argued private rights should be inferred and that they suffered wage-loss damages from Celadon’s deductions; Celadon argued no private cause of action exists, other enforcement remedies cover the statutes, and plaintiffs sustained no recoverable damages under those statutes.
- The Court granted summary judgment for Celadon, holding no private right of action exists under Section 2 or the Deduction Act and that plaintiffs would not recover damages under Section 2 even if a private right were implied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Section 2 of the Indiana Wage Assignment Act creates a private right of action | A private civil remedy should be inferred from legislative intent to benefit individuals | Statute provides criminal penalties and nullification but no civil remedy; Legislature did not intend private suit | No private right; summary judgment for Celadon |
| If private right under Section 2 exists, can plaintiffs recover damages for deductions/advances | Plaintiffs seek recovery for amounts deducted from wages for advances, fuel, fees, repairs, etc. | Even if a private right existed, statutory forfeiture/nullification could leave plaintiffs worse off; no recoverable damages | Even if implied, plaintiffs would not obtain damages; summary judgment for Celadon |
| Whether the Indiana Wage Deduction Act creates a private right of action | A private right should be inferred because the statute protects employees from unauthorized deductions | Deduction Act lacks an enforcement remedy; Payment Statute already provides a private remedy for unpaid wages | No implied private right under Deduction Act; enforcement lies via Payment Statute; summary judgment for Celadon |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
- Anderson v. Liberty Lobby, 477 U.S. 242 (genuine issue standard at summary judgment)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment burden on nonmoving party)
- Howard v. Regional Health Sys. v. Gordon, 952 N.E.2d 182 (Ind. 2011) (inference of private right of action governed by legislative intent)
- Blanck v. Indiana Dept. of Correction, 829 N.E.2d 505 (inference of private right requires individual (not public) benefit)
- St. Vincent Hosp. & Health Care Ctr., Inc. v. Steele, 766 N.E.2d 704 (Ind. 2002) (Payment Statute governs both frequency and amount of wages owed)
- GHPE Holdings, LLC v. Huxley, 69 N.E.3d 513 (Ind. Ct. App. 2017) (Payment Statute prevents employer from avoiding penalties by underpaying agreed wages)