Vaughn v. Phoenix House New York
957 F.3d 141
2d Cir.2020Background
- Vaughn entered a state-court–approved drug/alcohol rehabilitation program at Phoenix House in lieu of incarceration and returned to inpatient care in Feb. 2011 after a violation.
- While at Phoenix House (Apr. 2011–Jan. 2012) he alleges he was required to work roughly 8 hours/day, 6 days/week and was not paid.
- He remained in the program because a judge warned noncompliance would result in incarceration; Phoenix House provided housing, food, therapy, vocational training, and supervised work.
- Vaughn sued under the FLSA, New York Labor Law (NYLL), and 42 U.S.C. § 1983 alleging unpaid labor; the District Court dismissed.
- On initial appeal the Second Circuit affirmed dismissal of the § 1983 claim as untimely but vacated dismissal of the FLSA/NYLL claims and remanded for consideration under Glatt’s primary-beneficiary test; Vaughn filed a third amended complaint.
- On remand the District Court (and this Court on de novo review) held Vaughn was not an FLSA employee (he was the program’s primary beneficiary) and declined supplemental jurisdiction over NYLL claims; attempts to relitigate § 1983 are barred by the law-of-the-case doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Vaughn was an "employee" under the FLSA | Vaughn performed substantial uncompensated work and was compelled to work by program requirements and threat of incarceration | Phoenix House argued Vaughn was a treatment recipient, not an employee, and the relationship’s primary beneficiary was Vaughn | Not an employee; primary-beneficiary analysis (Glatt) favors Vaughn as the primary beneficiary, so no FLSA claim |
| Whether the District Court should retain supplemental jurisdiction over NYLL claims after FLSA dismissal | Vaughn sought to proceed on NYLL claims | Phoenix House argued dismissal of federal claims eliminated original jurisdiction | Court declined to exercise supplemental jurisdiction and dismissed NYLL claims |
| Whether § 1983 claim could be revived (state action/timeliness) | Vaughn argued continued state coercion because the judge ordered him to stay at Phoenix House after April 2011 | Phoenix House argued it is a private actor and prior decision held § 1983 untimely | Law-of-the-case bars relitigation; § 1983 claim remains untimely and fails because Phoenix House is not shown to be a state actor |
Key Cases Cited
- Glatt v. Fox Searchlight Pictures, Inc., 811 F.3d 528 (2d Cir. 2016) (adopts primary-beneficiary test for unpaid interns—applied here by analogy)
- Sybalski v. Indep. Grp. Home Living Program, Inc., 546 F.3d 255 (2d Cir. 2008) (tests for private entity state action under § 1983)
- Kolari v. N.Y.-Presbyterian Hosp., 455 F.3d 118 (2d Cir. 2006) (district court discretion to decline supplemental jurisdiction)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to pleading-stage deference)
- Mele v. Hill Health Ctr., 609 F. Supp. 2d 248 (D. Conn. 2009) (private treatment program not a state actor)