Middleton v. Richland County School District One
3:17-cv-02116
D.S.C.Oct 6, 2017Background
- Plaintiff Darryl Middleton, a South Carolina resident, worked for Richland County School District One as instructional/administrative support in the career and technology program under a 200‑day contract.
- Middleton attended summer professional development (Skills USA, Project Lead the Way) outside his contract term and was not paid for that time.
- Middleton sued in state court asserting violations of the South Carolina Payment of Wages Act (SCPWA) and quantum meruit; Defendant removed to federal court asserting federal-question jurisdiction based on the FLSA.
- Defendant moved to dismiss under Rule 12(b)(6) arguing the state claims are preempted by the FLSA and, alternatively, Plaintiff is an exempt teacher under the FLSA.
- Plaintiff moved to remand and argued his claims arise under state law and do not require adjudication under the FLSA.
- The court denied remand, found the claims preempted by the FLSA, held Plaintiff is an exempt professional/teacher, and granted Defendant’s motion to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether removal was proper / federal-question jurisdiction | Middleton says claims are purely state-law (SCPWA, quantum meruit) and belong in state court | Defendant says claims implicate compensable time/minimum wage under the FLSA, creating federal-question jurisdiction | Removal proper; FLSA preempts state claims, so federal jurisdiction exists |
| Whether SCPWA claim is preempted by the FLSA | SCPWA claim seeks unpaid wages under state law, not asserting FLSA rights | FLSA addresses compensable time and attendance at training; conflict preemption bars duplicative state claims | SCPWA claim preempted because it raises issues (compensable training time) governed by FLSA regulations |
| Whether quantum meruit claim is duplicative / preempted | Quantum meruit seeks value for services rendered (summer trainings) under state common law | Claim duplicates FLSA right to compensation for compensable time and thus is preempted | Quantum meruit is preempted as duplicative of FLSA remedies |
| Whether Plaintiff is exempt under the FLSA | Middleton contests applicability of FLSA or exemption; seeks leave to amend on compensable-work theory | Defendant shows Middleton’s duties, credentials, and required certification place him within the teacher/professional exemption | Court finds Middleton is a bona fide professional/teacher exempt from FLSA, so Defendant not liable even if FLSA applied |
Key Cases Cited
- Caterpillar Inc. v. Lewis, 519 U.S. 61 (U.S. 1996) (party invoking removal burden to show federal jurisdiction)
- Mulchaey v. Columbia Organic Chems. Co., 29 F.3d 148 (4th Cir. 1994) (doubtful federal jurisdiction requires remand)
- Anderson v. Sara Lee Corp., 508 F.3d 181 (4th Cir. 2007) (FLSA enforcement scheme can preempt state claims asserting FLSA rights)
- Kendall v. City of Chesapeake, 174 F.3d 437 (4th Cir. 1999) (discussing FLSA preemption of state-law claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standard: factual matter must state a plausible claim)