Greg Landers v. Quality Communications, Inc.
771 F.3d 638
| 9th Cir. | 2014Background
- Landers sued Quality Communications, Inc. for FLSA minimum wage and overtime violations on his own behalf and for similarly situated employees.
- The district court dismissed the complaint under Rule 12(b)(6), finding the pleading insufficient under Twombly/Iqbal to state a plausible claim.
- Landers alleged a “de facto piecework no overtime” wage system and/or improper overtime payments and payroll falsifications.
- The court applied Twombly/Iqbal, concluding the complaint lacked factual specifics such as overtime hours, hourly rate, or unpaid overtime amounts.
- The Ninth Circuit affirmed, agreeing that a FLSA claim requires more than bare statutory recitals and that a workweek with excess unpaid overtime must be alleged.
- Landers declined to amend, and the court did not remand for amendment, affirming dismissal for failure to state a plausible claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Landers state a plausible FLSA claim post-Twombly/Iqbal | Landers argues defendants denied minimum and overtime wages under FLSA. | Quality contends the complaint lacks a specific week with >40 unpaid overtime. | Yes; Landers failed to plead a single week with >40 hours unpaid. |
Key Cases Cited
- Probert v. Family Centered Servs. of Alaska, Inc., 651 F.3d 1007 (9th Cir. 2011) (analyze FLSA pleading under Rule 8 and substantiate overtime claims)
- Lundy v. Catholic Health System of Long Island Inc., 711 F.3d 106 (2d Cir. 2013) (requires pleading a workweek with 40+ hours and unpaid overtime to state a claim)
- Nakahata v. New York-Presbyterian Healthcare System, Inc., 723 F.3d 192 (2d Cir. 2013) (rejects mere allegations of unpaid overtime without a specific 40+ hour workweek)
- Dejesus v. HF Management Services, LLC, 726 F.3d 85 (2d Cir. 2013) (emphasizes Lundy’s pleading standard for overtime claims)
- Pruell v. Caritas Christi, 678 F.3d 10 (1st Cir. 2012) (permits plausible FLSA claims with context showing potential overtime without mathematical precision)
- Davis v. Abington Memorial Hospital, 765 F.3d 236 (3d Cir. 2014) (post-Twombly/Iqbal context for overtime pleading is context-specific)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (S. Ct. 2007) (establishes plausibility standard for Rule 8 claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (S. Ct. 2009) (requires factual content showing plausible relief and rejects bare recitals)