113 F.4th 300
2d Cir.2024Background
- Robert Guthrie was employed by Rainbow Fencing Inc. (RFI) as a welder in New York from 2014 to 2021.
- Guthrie filed suit claiming unpaid wages (including overtime) under the Fair Labor Standards Act (FLSA) and also sought statutory damages under New York Labor Law § 195 for RFI’s failure to provide wage notices and statements.
- RFI did not respond, and a default judgment was entered for unpaid wages, but Guthrie’s claim for statutory damages for failure to provide wage notices/statements was dismissed for lack of standing.
- The district court ruled that Guthrie had not alleged a concrete injury (injury-in-fact) related to the absence of wage notices or statements.
- On appeal, Guthrie argued that Article III standing should not be required for the state-law claim due to supplemental jurisdiction, and alternatively, that he did allege injury-in-fact.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Article III standing required for state-law statutory damages claims in federal court even if there is supplemental jurisdiction? | Supplemental jurisdiction allows federal court to hear related state claim without separate Article III injury. | Plaintiff must still show Article III standing for every claim, including state-law ones. | Article III standing required for every claim; supplemental jurisdiction does not bypass this requirement. |
| Whether technical violations of NY Labor Law § 195 (failure to provide wage notices/statements) without concrete injury confer standing? | Guthrie argued technical violation and legislative intent suffice for injury. | Concrete injury is required; mere statutory violation is not enough. | Technical/statutory violations alone do not create standing; concrete injury is needed. |
| Does alleging potential informational or procedural harm from lack of wage notices/statements meet the standing requirement? | Plaintiff described how missing notices could cause various harms. | No specific harm to Guthrie alleged; only hypothetical injuries asserted. | Plaintiff must plausibly allege he suffered an actual, concrete harm. |
| Did Guthrie allege any plausible injury-in-fact linked to RFI’s failure to provide required notices/statements? | His complaint included only generic assertions and a demand for statutory damages. | Defendants argued no factual link to actual harm was present in the complaint. | Guthrie did not allege concrete injury tied to the violation; thus, lacked standing for this claim. |
Key Cases Cited
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (2006) (plaintiff must demonstrate standing for each claim; supplemental jurisdiction doesn't override Article III)
- TransUnion LLC v. Ramirez, 594 U.S. 413 (2021) (standing requires concrete injury even for statutory violations; no harm, no standing)
- Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (Article III requires real, not just procedural, injury)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing elements must be plausibly alleged with facts)
- Town of Chester v. Laroe Estates, Inc., 581 U.S. 433 (2017) (plaintiff must show standing for each claim and form of relief)
- Maddox v. Bank of New York Mellon Trust Co., N.A., 19 F.4th 58 (2d Cir. 2021) (plaintiff must plausibly allege the kind of injury for statutory damages relief)