Pruell v. Caritas Christi, 678 F.3d 10

Pruell and Gordon filed a Sept. 2009 complaint in Massachusetts federal court against Caritas Christi network and related entities and executives alleging under-compensation for meal-break, pre/post-shift, and training-time.
Claims asserted under FLSA (minimum wage and overtime), ERISA (record-keeping and hours worked), and RICO (mail fraud).
FLSA claim was pursued as a collective action under §216(b); district court later deemed it inadequately pled.
Amendment in Oct. 2010 added a general allegation that named plaintiffs and others regularly worked over 40 hours; no concrete hourly details provided.
In July 2011 the district court again found the FLSA claim deficient, and denied further amendment, dismissing with prejudice.
First Circuit reviews de novo the district court’s dismissal and abuse-of-discretion for the denial of leave to amend; the court affirms in part, vacates the prejudice dismissal, and remands for a final amended complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FLSA claim was adequately pled	Pruell argued the amended pleadings alleged >40 hours and unpaid time sufficiently.	Caritas contended the pleadings remained too vague about hours, pay calculations, and specific employment details.	FLSA claim inadequately pled; remanded for further amendment
Whether amendment should be allowed to cure pleading defects	Plaintiffs asserted additional details could be supplied; some facts in control of defendants.	Defendants contended the amendments still lacked specifics and showed no under-compensation.	Amendment should be allowed; final amended complaint to address remaining deficiencies on remand
Whether dismissal with prejudice was appropriate equal to leave to amend	No prejudice if plaintiffs are given one more opportunity to amend with specifics.	Dismissal with prejudice was appropriate given persistent lack of specifics.	Dismissal with prejudice vacated; remand for a final viable amended complaint

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Supreme Court 2007) (pleading must contain plausible factual assertions)
Ashcroft v. Iqbal, 129 S. Ct. 1937 (Supreme Court 2009) (pleadings require more than conclusory statements)
Peñalbert-Rosa v. Fortuño-Burset, 631 F.3d 592 (1st Cir. 2011) (threadbare or speculative allegations fail to state a claim)
Plumbers' Union Local No. 12 Pension Fund v. Nomura Asset Acceptance Corp., 632 F.3d 762 (1st Cir. 2011) (plaintiff must plead plausible claim with factual enhancements)
Estate of Bennett v. Wainwright, 548 F.3d 155 (1st Cir. 2008) (contextual review standard for pleadings)
Universal Commc'n Sys., Inc. v. Lycos, Inc., 478 F.3d 413 (1st Cir. 2007) (notice pleading and plausibility standards in complex litigation)
Maldonado v. Fontanes, 568 F.3d 263 (1st Cir. 2009) (clarifies evaluation of factual pleading under Iqbal and Twombly)