Oram v. SoulCycle LLC, 979 F. Supp. 2d 498

Background

Plaintiff Nick Oram was an indoor cycling instructor for SoulCycle from April 2009 to April 15, 2013 and taught classes in New York and California locations.
Oram claims he was paid per class (not hourly), performed additional unpaid tasks (training, playlist compilation, meetings, marketing) averaging 15–25 extra hours weekly, and incurred unreimbursed business expenses (MP3 players, software, travel).
Oram filed a putative class action (Amended Complaint) asserting New York wage-and-hour claims (minimum wage, unpaid wages, unlawful deductions, wage statements, NY retaliation) and California Labor Code claims (various wage and reimbursement statutes).
Defendants moved to sever California claims and defendants, to dismiss New York claims (first three causes of action), and to strike portions of the AC; the court considered employment documents (offer/contract) integral to the pleading.
The contract contained a broad services/compensation clause (compensation for all services, listing many of the tasks Oram alleged were unpaid), and the offer letter reflected per-class rates (e.g., $130/class, 11+ classes/week), which the court used to assess plausibility of wage claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to sever California claims and parties under Fed. R. Civ. P. 21	Oram alleges common practice/policy across locations; claims arise from same conduct so should remain together for efficiency	Different states’ laws and out-of-state parties/witnesses justify severance to avoid jury confusion and inconvenience	Denied without prejudice: severance premature given discovery has not developed and common-policy allegation suffices to proceed together
Whether the NY minimum-wage and related NYLL claims (1st–3rd) are plausibly pled	Oram alleges per-class pay did not cover non-class hours and unreimbursed expenses reduced wages below minimum	Offer/contract and AC show per-class rates that likely exceed minimum wage; no factual detail on hours, weekly pay, or expense amounts to show below-minimum effect	Granted: first, second, and third causes dismissed for failure to plead specific facts showing wages fell below statutory minimum or that expenses reduced pay below minimum
Whether NYLL § 215 retaliation claim survives dismissal	Oram alleges post-complaint ban from SoulCycle premises (after employment ended) as retaliation for filing suit	Defendants argue § 215 protects only current employees and ban is not an actionable adverse employment action	Denied as to dismissal: court finds former employees can be protected under § 215 (following Robinson and Liverpool reasoning) and the ban raises a triable issue whether a reasonable worker would be dissuaded — survives motion to dismiss
Whether portions of the AC should be stricken under Rule 12(f)	Plaintiff included allegations characterizing treatment of customers and colorful rhetoric to describe practices	Defendants seek removal of prejudicial, irrelevant, and scandalous matter	Granted in part, denied in part: immaterial allegations about customer mistreatment stricken; colorful/colloquial language allowed as non-prejudicial opinionary rhetoric

Key Cases Cited

In re NYSE Specialists Sec. Litig., 503 F.3d 89 (2d Cir.) (treating documents integral to the complaint on a motion to dismiss)
Chambers v. Time Warner, Inc., 282 F.3d 147 (2d Cir.) (courts may consider documents integral to the complaint without converting to summary judgment)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard requires factual allegations that plausibly state a claim)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
Lundy v. Catholic Health Sys. of Long Island, Inc., 711 F.3d 106 (2d Cir.) (dismissing overtime claims for insufficient factual detail)
Robinson v. Shell Oil Co., 519 U.S. 337 (1997) (antiretaliation provisions should be read to protect former employees to preserve remedial access)