Maclin v. Reliable Reports of Tex., Inc.
314 F. Supp. 3d 845
N.D. Ohio2018Background
- Defendant Reliable Reports of Texas, Inc. is a Texas corporation headquartered in Texas; ~438 employees nationwide, 14 in Ohio.
- Plaintiff Harold Maclin is an Ohio resident who worked for Reliable as an Inspector (July 2016–2017) and alleges inspectors routinely worked 50–60 hours/week without overtime premium pay.
- Maclin sued under the FLSA as a nationwide collective and under Ohio wage law (OMFWSA) as a state class; amended complaint limited the Ohio class to Ohio inspectors but retained a nationwide FLSA collective.
- Reliable moved to dismiss: (1) for lack of personal jurisdiction over non-Ohio plaintiffs’ FLSA claims, and (2) for failure to state a claim under Rule 12(b)(6) for the federal and state overtime claims.
- The district court concluded it lacked specific personal jurisdiction over non-Ohio plaintiffs’ FLSA claims and dismissed those claims for lack of jurisdiction, but denied dismissal under Rule 12(b)(6) as to the remaining state and Ohio-based federal overtime claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has personal jurisdiction over non-Ohio plaintiffs’ FLSA claims | Maclin: Bristol-Myers should not bar nationwide FLSA collective suits; FLSA is national in scope and Congress authorized collective suits | Reliable: Bristol-Myers requires a connection between forum and claim; non-Ohio plaintiffs’ claims lack ties to Ohio | Court: Bristol-Myers applies; no personal jurisdiction over non-Ohio plaintiffs’ FLSA claims — dismissed under Rule 12(b)(2) |
| Whether complaint states plausible FLSA and Ohio wage-act claims under Twombly/Iqbal | Maclin: alleged employment dates, routine 50–60 hr weeks, piece-rate pay for overtime, and failure to keep records suffice to plead plausible claims | Reliable: courts demand detailed pleading (specific weeks/hours) to survive 12(b)(6) | Court: allegations are sufficient; denies Rule 12(b)(6) dismissal of remaining state and federal overtime claims |
Key Cases Cited
- Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (specific-jurisdiction limits where claims lack connection to forum)
- Daimler AG v. Bauman, 134 S. Ct. 746 (2014) (general jurisdiction limited to a corporation’s place of incorporation and principal place of business except in extraordinary cases)
- BNSF Ry. Co. v. Tyrrell, 137 S. Ct. 1549 (2017) (reaffirming limits on general jurisdiction despite substantial in-state operations)
- Goodyear Dunlop Tires Operations v. Brown, 131 S. Ct. 2846 (2011) (corporate "at home" forum discussion)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must be plausible, not merely conceivable)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to assumption of truth in plausibility analysis)
- Conn v. Zakharov, 667 F.3d 705 (6th Cir. 2012) (Ohio long-arm statute is not coterminous with Due Process Clause)