283 F. Supp. 3d 967
W.D. Wash.2017Background
- GEO Group operates the Northwest Detention Center in Tacoma under a contract with ICE and runs a Voluntary Work Program that compensates detainees $1/day (or improved food) for tasks like laundry and cleaning.
- Washington (as parens patriae) sued GEO seeking disgorgement for unjust enrichment and declaratory/injunctive relief that GEO must pay detainees the State minimum wage under the Washington Minimum Wage Act (WMWA).
- GEO moved to dismiss under Fed. R. Civ. P. 12(b)(6) on grounds of federal preemption (IRCA/ICE authority), lack of State authority to sue, failure to state claims (unjust enrichment and WMWA employee status), and equitable defenses (unclean hands, laches).
- The operative Contract and ICE Performance-Based National Detention Standards (Voluntary Work Program) prescribe detainee work rules and a minimum $1/day compensation, but ICE policy and contract provisions do not expressly preempt state wage law.
- The court treated the complaint allegations as true and denied GEO’s motion to dismiss: found no clear congressional or agency intent to preempt state minimum wage law as applied to detainee wages; held Washington may sue in parens patriae; and concluded the complaint plausibly states claims for unjust enrichment and WMWA violations. Dismissal on equitable defenses was premature.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal law (IRCA/ICE authority) preempts Washington’s minimum-wage claims | State: No. Congress/ICE have not manifested intent to preempt state minimum-wage law for detainee wages; ICE policy lacks force to preempt. | GEO: IRCA (and federal detention uniformity) preempts state sanctions/liability and ICE contract/policy governs detainee wages. | Denied: No express, field, or conflict/obstacle preemption shown on pleadings; factual issues remain for later stages. |
| Whether Washington has authority to sue (parens patriae) | State: Has quasi-sovereign interests in economic/health welfare, an interest distinct from private parties, and alleges injury to a substantial segment of population. | GEO: Challenges parens patriae on standing/authority grounds (and cites ballot initiative as evidence people oppose extending wages to detainees). | Granted to State: Parens patriae authorization plausible on the pleadings; ballot initiative irrelevant. |
| Whether complaint states an unjust enrichment claim | State: Detainees conferred benefit by working below state minimum wage; enrichment is unjust and State sues on behalf of affected residents. | GEO: Pleading fails because detainee work is voluntary, no reasonable expectation of state-wage, and State did not directly confer benefit. | Denied: On pleadings, involuntariness and expectations present factual disputes; State’s parens patriae role suffices to allege benefit. |
| Whether detainees are "employees" under Washington law (WMWA) | State: WMWA definition of "employee" plausibly includes detainees at a federal facility; statutory exception applies only to state/county/municipal facilities. | GEO: Detainees fall into the statutory exception for inmates/residents of detention institutions or FLSA precedent excludes detainees. | Denied: Statutory exception refers to state/local facilities only; on pleadings it is plausible detainees are employees under state law. |
| Whether equitable defenses (unclean hands/laches) bar relief | State: Not addressed beyond procedural sufficiency; claims premature. | GEO: State’s conduct (legislative carve-outs; L&I enforcement delay) shows bad faith and delay that should bar relief. | Denied: Affirmative equitable defenses raise factual issues inappropriate to resolve on 12(b)(6) motion. |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim for relief)
- Alfred L. Snapp & Son, Inc. v. Puerto Rico, 458 U.S. 592 (parens patriae standing framework)
- Arizona v. United States, 567 U.S. 387 (field preemption principles)
- Chamber of Commerce of U.S. v. Whiting, 563 U.S. 582 (IRCA preemption analysis context)
- Nat'l Fed'n of the Blind v. United Airlines Inc., 813 F.3d 718 (preemption analysis and defining pertinent regulatory field)