Pridgen v. Appen Butler Hill, Inc.
1:18-cv-00061
| D. Maryland | Apr 23, 2018Background
- Plaintiff Chad Wenzlick Pridgen worked for Appen Butler Hill, Inc. beginning in 2010 and alleges he was paid improperly after being classified as a subcontractor.
- Pridgen alleges federal FLSA claims (misclassification and unpaid overtime), Maryland statutory wage claims, an FLSA retaliation claim, and a Maryland common‑law quantum meruit claim for unpaid work.
- Defendant removed the case to federal court and moved to dismiss Count IV (quantum meruit), arguing it is preempted by the FLSA or barred by an express contract.
- At the Rule 12(b)(6) stage, the court accepts Pridgen’s factual allegations as true and evaluates only legal sufficiency.
- The court recognized the FLSA’s enforcement scheme can preempt state common‑law remedies that would short‑circuit federal enforcement, but also that Rule 8(d) permits pleading alternative and inconsistent claims.
- The court denied the motion to dismiss Count IV, concluding Pridgen may plead an alternative quantum meruit claim (if he was a subcontractor) alongside his FLSA claim (if he was an employee).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether quantum meruit claim (Count IV) must be dismissed as preempted by the FLSA | Pridgen contends he can plead quantum meruit in the alternative to statutory claims for unpaid work | Appen argues the FLSA’s enforcement scheme preempts state common‑law claims for the same unpaid‑wage allegations | Denied — plaintiff may plead alternative theories; FLSA preempts duplicative remedies, but alternative quantum meruit is permitted at pleading stage |
| Whether an express contract bars quantum meruit | Pridgen alleges unjust enrichment for unpaid work and disputes existence/coverage of any contract | Appen asserts an express contract governs and thus forecloses quasi‑contract recovery | Denied — whether an express contract covers the subject is a disputed factual question inappropriate to resolve on a motion to dismiss |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
- Anderson v. Sara Lee Corp., 508 F.3d 181 (4th Cir. 2007) (FLSA enforcement scheme can preempt state claims that obstruct federal goals)
- Kendall v. City of Chesapeake, 174 F.3d 437 (4th Cir. 1999) (discussing exclusivity of FLSA enforcement)
- FLF, Inc. v. World Publ’ns, 999 F. Supp. 640 (D. Md. 1998) (quantum meruit barred where an express contract covers the subject matter)
- Sosnowy v. A. Perri Farms, Inc., 764 F. Supp. 2d 457 (E.D.N.Y. 2011) (permitting alternative statutory and common‑law wage claims at pleading stage)
- Swedish Civil Aviation Admin. v. Project Mgmt. Enters., 190 F. Supp. 2d 785 (D. Md. 2002) (permitting pleading of contract and quasi‑contract in the alternative when contract existence/disposition is disputed)