Chen v. Major League Baseball
6 F. Supp. 3d 449
| S.D.N.Y. | 2014Background
- Plaintiff John Chen sues MLB Properties and the Office of the Commissioner under the FLSA and NYLL for alleged minimum wage violations during FanFest at the Javits Center in July 2013.
- FanFest and All Star Week activities were staffed generally by volunteers who received in-kind benefits rather than cash wages.
- Chen worked about 17 hours over three shifts and attended mandatory sessions prior to his shifts.
- Chen seeks conditional certification under FLSA § 216(b) for a collective of similarly situated volunteers and court-approved notice.
- Defendants move to dismiss the First Amended Complaint; Chen moves for collective certification; the court also addresses related NYLL claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FLSA exemption applies to bar minimum wage claims | Chen argues exemption does not apply because he worked for MLB, not FanFest, and discovery may be needed. | MLB contends FanFest was an amusement or recreational establishment operating for fewer than eight months, triggering the exemption. | Exemption applies; FLSA claims are dismissed. |
| Whether Chen is an employee covered by the FLSA | Chen argues he was an employee entitled to minimum wage protections. | MLB argues the exemption applies regardless of employee status, since the establishment exemption controls. | Not reached; court ruled on exemption as dispositive. |
| Whether NYLL claims survive after FLSA dismissal | Chen asserts NYLL claims remain to be litigated. | Defendants contend NYLL claims should be dismissed or adjudicated with federal claims. | NYLL claims dismissed without prejudice. |
| Whether to grant collective certification and court-approved notice | Chen seeks conditional certification for a broad class of All Star Week volunteers. | With FLSA claims dismissed, certification would be moot. | Denied as moot. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (U.S. 2009) (facial plausibility required for claims)
- Pani v. Empire Blue Cross Blue Shield, 152 F.3d 67 (2d Cir. 1998) (affirmative defenses like exemptions must appear on the face of the complaint at 12(b)(6))
- Jeffery v. Sarasota White Sox, Inc., 64 F.3d 590 (11th Cir. 1995) (establishment concept under amusement or recreational exemption)
- Brennan v. Yellowstone Park Lines, Inc., 478 F.2d 285 (10th Cir. 1973) (exemption purpose and seasonal nature of establishments)
- Chao v. Double JJ Resort Ranch, 375 F.3d 393 (6th Cir. 2004) (ambiguous language of amusement or recreational establishment exemption)