Ritchie v. St. Louis Jewish Light
630 F.3d 713
| 8th Cir. | 2011Background
- Ritchie, a former employee of St. Louis Jewish Light, filed a federal FLSA retaliation claim against Levin and the company.
- Ritchie alleged Levin directed her to perform work without recording overtime, with overtime hours subsequently recorded by Ritchie.
- Ritchie was terminated after she continued to record overtime contrary to Levin's instruction.
- The district court dismissed the claim, concluding informal employer complaints are not protected under § 215(a)(3).
- Ritchie argued that informal complaints to her employer triggered FLSA anti-retaliation protection, and that she was retaliated against for recording overtime.
- The Eighth Circuit affirmed dismissal, holding Ritchie failed to plead facts showing she engaged in statutorily protected activity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are informal complaints protected activity under § 215(a)(3)? | Ritchie contends informal complaints trigger protection. | Defendants argue only explicit statutory complaints are protected. | Court avoids ruling on informals; not necessary to decide. |
| Did Ritchie plead sufficient facts of statutorily protected activity and causation for retaliation? | Ritchie asserts retaliation for recording overtime after admitting complaint. | No protected complaint pleaded; retaliation claim not plausible. | Complaint failed to show statutorily protected activity or causal link. |
Key Cases Cited
- Grey v. City of Oak Grove, 396 F.3d 1031 (8th Cir. 2005) (sets prima facie retaliation framework)
- Northstar Indus., Inc. v. Merrill Lynch & Co., 576 F.3d 827 (8th Cir.2009) (pleading must be plausible under Iqbal/Twombly)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (S. Ct. 2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (clarifies plausibility standard)
- Carton v. Gen. Motors Acceptance Corp., 611 F.3d 451 (8th Cir. 2010) (de novo review on 12(b)(6) dismissal)