Helfand v. W.P.I.P., Inc., 165 F. Supp. 3d 392

Plaintiff Carl Helfand worked for WPIP from Jan 2, 2014 to Aug 20, 2015 as an office clerk and security guard; his duties included bill collection, customer service, groundskeeping, and facility/security inspections for a business serving truck drivers.
Plaintiff alleges Defendants told him he would not receive overtime and paid only straight time or only 40 hours weekly despite his routinely working 50–60 hours, continuing through termination in Aug 2015.
Plaintiff sued under the FLSA, the Maryland Wage and Hour Law (MWHL), and the Maryland Wage Payment and Collection Law (MWPCL).
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6), arguing the FLSA claims fail because WPIP is not covered (enterprise coverage <$500,000) and Plaintiff was not individually engaged in interstate commerce; they attached financial statements.
Court treated the motion under Rule 12(b)(6), declined to convert to summary judgment (excising extra-pleading affidavits), accepted Plaintiff’s well-pleaded allegations, and denied the motion to dismiss to permit discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FLSA enterprise coverage applies	WPIP’s annual dollar volume exceeds $500,000; thus enterprise coverage attaches	WPIP’s financials show < $500,000 in revenue (2014/2015), so no enterprise coverage	Denied dismissal; court accepts Plaintiff’s pleaded allegation and permits discovery on revenue; Defendants’ accounting documents insufficient at pleading stage
Whether Plaintiff qualifies for individual FLSA coverage (engaged in commerce)	Helfand alleges his duties (clerical, customer service, security) were tied to trucking operations and interstate commerce	Plaintiff’s duties were local and not sufficiently related to interstate commerce	Denied dismissal; plausible that his work was "so directly and vitally related" to instrumentalities of interstate commerce to survive pleading stage
Whether to dismiss co-defendant Einstein	Plaintiff alleges Einstein was a co-owner and employer	Defendants claim Manus Suddreth is sole owner and Einstein not employed, offering no affidavits proving that	Denied dismissal of Einstein at this stage; Defendants may renew with proper evidence later
Whether court should exercise supplemental jurisdiction over state claims if FLSA fails	N/A (Defendants did not press state-law dismissal if FLSA stands)	Defendants alternatively sought to dismiss state claims if FLSA dismissed	Court did not dismiss state claims; FLSA claim survives so supplemental jurisdiction remains appropriate for now

Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility and dismissal standard)
Mitchell v. Lublin, 358 U.S. 207 (scope of FLSA coverage and congressional intent)
Wirtz v. Modern Trashmoval, Inc., 323 F.2d 451 (test whether employee is "engaged in commerce")
Crook v. Bryant, 265 F.2d 541 (night watchman deemed engaged in commerce)
Chao v. Hotel Oasis, Inc., 493 F.3d 26 (definition of FLSA coverage not jurisdictional)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standards and discovery before SJ)
Harrods Ltd. v. Sixty Internet Domain Names, 302 F.3d 214 (summary judgment generally inappropriate before discovery)