Chuck W. Adams, Charles E. Howard v. ArvinMeritor, Inc.
2016 Ind. LEXIS 716
| Ind. | 2016Background
- Chuck Adams and Charles Howard were inmates at the Correctional Industrial Facility (CIF) and worked at a privately run brake shop on CIF grounds operated by Meritor Heavy Vehicle Systems, LLC and related entities.
- Indiana Code ch. 11-10-7 authorizes the DOC commissioner to permit private enterprises to operate within state correctional facility boundaries and requires that an offender employed by a private person be paid at least the prevailing wage for that work, including overtime (I.C. § 11-10-7-2, -3).
- Adams and Howard sued, alleging they were not paid the statutory “prevailing wage,” seeking to recover unpaid wages under state law.
- Meritor and State defendants moved to dismiss, arguing ch. 11-10-7 does not create a private right of action for offenders to enforce wage claims; the trial court granted dismissal.
- A majority of the Indiana Court of Appeals reversed, concluding offenders have a private right of action under I.C. § 11-10-7-4 because enterprises operating under the statute are subject to laws governing similar enterprises (including the Wage Payment Statute).
- The Indiana Supreme Court granted transfer, agreed with the dissent below, and affirmed the dismissal of the wage claims, holding the statute did not create a private right of action. The Court summarily affirmed other parts of the Court of Appeals’ opinions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether I.C. ch. 11-10-7 creates a private right of action for offenders to enforce prevailing-wage claims | Adams: ch. 11-10-7 (esp. § 11-10-7-4) makes private enterprises subject to applicable laws, so offenders may sue under wage statutes | Meritor/State: the statute does not explicitly create a private cause of action; enforcement is not intended via private suits | Court: No private right of action; dismissal affirmed |
Key Cases Cited
- Adams v. ArvinMeritor, Inc., 48 N.E.3d 1 (Ind. Ct. App. 2015) (Court of Appeals majority holding offenders may sue for unpaid prevailing wages under ch. 11-10-7)
- Adams v. ArvinMeritor, Inc., 53 N.E.3d 1182 (Ind. Ct. App. 2016) (Court of Appeals rehearing decision reaffirming majority view; later incorporated and reversed by Indiana Supreme Court)