Galloway v. Chugach Government Services, Inc.
199 F. Supp. 3d 145
| D.D.C. | 2016Background
- Plaintiffs Carolyn Galloway, Desiree McKeiver, and Carlette Ososanya are current/former Resident Advisors employed by Chugach Government Services at the Potomac Job Corps dormitories; about 20 similarly situated employees are implicated.
- Scheduled as five 8-hour shifts per week (each shift a 9-hour block with a 1-hour meal break), Plaintiffs allege frequent uncompensated work: working through meal breaks 3–5 times/week, staying 20–30 minutes after shifts waiting for relief 4–5 days/week, and regularly working more than five shifts/week without overtime pay.
- Plaintiffs assert they and similarly situated employees worked at least 250 hours of overtime per year during the relevant three-year period.
- Claims: violations of the Fair Labor Standards Act (FLSA) and the D.C. Minimum Wage Act (DCMWA); seek unpaid overtime, liquidated damages, prejudgment interest, and attorneys’ fees.
- Chugach moved to dismiss for inadequate factual detail on hours, timekeeping policy, notice/complaints, and on the alleged willfulness (affecting the three-year statute of limitations).
- Holding: The Court denied the motion to dismiss, concluding Plaintiffs pleaded sufficient facts under Rule 8 to state plausible FLSA and DCMWA claims and sufficiently alleged willfulness to invoke the three-year limitations period.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of FLSA/DCMWA pleading | Complaint alleges employment, coverage, working >40 hours, and failure to pay overtime with specific factual contexts (meal breaks, post-shift waiting, >5 shifts/week) | Complaint lacks detailed quantification of overtime hours, timekeeping policy, complaints made, responses, and pay rates | Court: Rule 8 does not require detailed hour-by-hour allegations; pleaded facts are plausible and give fair notice — claim survives dismissal |
| Whether FLSA requires special pleading particularity | Plaintiffs: ordinary Rule 8 plausibility standard applies; no special FLSA-specific specificity required | Chugach: some courts require more particularized allegations of overtime hours and circumstances | Court: No special pleading rule for FLSA; demanding such detail would be inconsistent with Rule 8 and precedent |
| Willfulness (three-year statute of limitations) | Plaintiffs: alleged employer awareness of FLSA requirements and practices that avoided overtime (e.g., denying approval, payroll system blocking >40 hours) support inference of willfulness | Chugach: allegations are conclusory; plaintiffs have not pleaded facts showing employer knew or recklessly disregarded FLSA obligations | Court: Allegations (policies denying overtime, payroll constraints, routine denial of approval) permit plausible inference of willfulness; sufficient to survive dismissal |
| Scope of DCMWA claim relative to FLSA | Plaintiffs: DCMWA largely mirrors FLSA; success on FLSA supports DCMWA claim | Chugach: if FLSA claim fails, DCMWA fails too | Court: Sufficiency of FLSA and DCMWA rise/fall together; because FLSA claim stands, DCMWA claim survives dismissal |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a claim that is plausible on its face)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility and fair notice under Rule 8)
- McLaughlin v. Richland Shoe Co., 486 U.S. 128 (1988) (FLSA willfulness requires knowing or reckless disregard)
- Hishon v. King & Spalding, 467 U.S. 69 (1984) (pleading-stage standard; allegations taken as true)
- Blue v. District of Columbia, 811 F.3d 14 (D.C. Cir. 2015) (discussing adequacy of factual support under Iqbal/Twombly)