957 F. Supp. 2d 44
D. Me.2013Background
- Dinan was awarded $70,331.93 for quasi-contract damages and $7,799.67 for thirty days’ wages by the jury.
- Plaintiff sued Alpha Networks, Inc. in Maine federal court, alleging Maine’s wage payment law and related claims.
- A California choice-of-law provision in Dinan’s 2005 Employment Agreement governs the employment relationship terms.
- The court questioned which state’s law applies to the quasi-contract damages (not breach of contract), triggering a Maine conflict-of-laws analysis.
- Maine Law Court later held Maine’s §626 may apply to quantum meruit if the services are the type for which wages would be due.
- The court ultimately applied California law to the quasi-contract damages and Maine law for pre-judgment interest, with California penalties and Maine treble-damages considerations addressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which state's law governs the quantum meruit damages? | Dinan argues Maine law governs due to lack of a controlling contract, applying Burr §188 (Restatement). | Alpha argues California law applies via the Employment Agreement's choice-of-law provision to all contract-related terms, including quasi-contract. | California law applies to the quantum meruit damages. |
| Whether California waiting-time penalties apply to the damages | The jury award includes thirty days’ wages; California penalties may apply if willful nonpayment. | California requires a willful or good faith dispute defense; no good-faith defense was properly presented to the jury. | Waiting-time penalties under California Labor Code § 203 apply to the quasi-contract damages. |
| Pre-judgment interest on the damages | Dnan seeks Maine 14 M.R.S. § 1602-B pre-judgment interest from filing date. | Interest should be limited to the quantum meruit award, not the penalty. | Pre-judgment interest awarded on the quantum meruit award under Maine § 1602-B; not on the liquidated damages penalty. |
| Treble damages and attorney’s fees under Maine § 626 | Treble damages and attorney’s fees may apply if Maine law governs the quantum meruit. | Treasury options under Maine § 626 do not apply given the good-faith dispute and contractual analysis. | Treble damages and attorney’s fees under Maine § 626 are denied. |
Key Cases Cited
- Schroeder v. Rynel, Ltd., Inc., 1998 ME 259, 720 A.2d 1164 (Me. 1998) (enforces contractual choice-of-law if substantial relationship and not contrary to Maine policy)
- Nedlloyd Lines B.V. v. Superior Court, 3 Cal.4th 459, 11 Cal.Rptr.2d 330, 834 P.2d 1148 (Cal. 1992) (contractual clause 'governs' all related claims and applies broadly)
- JMP Securities LLP v. Altair Nanotechnologies Inc., 880 F. Supp. 2d 1029 (N.D. Cal. 2012) (California tolls choice-of-law to all claims arising from or related to the contract)
- Okmyansky v. Herbalife Int’l of Am., Inc., 415 F.3d 154 (1st Cir. 2005) (confirms conflict-of-laws framework and extent of choice-of-law application)