Plaintiff’s Factual Allegations
Plaintiff Austin Moore sued his prior employer Auto Assure, alleging the company failed to pay him overtime wages during his employment as a Sales Representative from approximately March 2018 until February 2022. Moore claims that he was directed to work overtime weekly and was promised overtime pay for these extra hours. Yet he alleges that Auto Assure displayed incorrect overtime hours on his paychecks and never compensated him for these hours. Moore also asserts that he was required to work on “Team Saturdays” without compensation, despite promises to the contrary from his supervisor and manager. The complaint asserts two counts against Auto Assure: failure to pay overtime wages in violation of the Fair Labor Standards Act (FLSA) and the Missouri Minimum Wage Law (MMWL), seeking over $150,000 in unpaid overtime.
Court’s Rulings on the Arguments
FLSA Claim and Statute of Limitations: The defendant moved to limit the plaintiff’s FLSA claim to a two-year statute of limitations, arguing that there was no evidence of a willful violation, which would otherwise extend the statute to three years. The court rejected this argument, citing the Eighth Circuit precedent in Weatherly v. Ford Motor Co. It held that the complaint does not establish that the alleged violations were not willful. The court found that Moore’s allegations, including promises of overdue payment and incorrect paychecks, could demonstrate willfulness, thus denying the motion to dismiss based on a two-year statute of limitations.
Three-Year Statute of Limitations:The defendant alternatively argued that the plaintiff’s claims should be limited to the three-year statutes of limitations under both the FLSA and MMWL. The court agreed that the claims are limited by these three-year statutes. Claims that accrued more than three years before the lawsuit filing are barred, as these limitations are enforceable by the passage of time alone, regardless of the defendant’s state of mind.
Equitable Tolling and Equitable Estoppel: The plaintiff argued for equitable tolling of the statute of limitations due to the defendant’s alleged misconduct. The court found that equitable tolling does not apply since the plaintiff had actual knowledge of the possible violations upon receiving his paychecks. The court also noted that the plaintiff did not establish diligent pursuit of his rights. As for equitable estoppel, the court determined that the plaintiff did not demonstrate that the defendant’s misconduct lulled or tricked him into missing the filing deadline. The allegations of misconduct are essentially the basis for the overtime claims and do not go “above and beyond” the underlying wrongdoing.
Conclusion The court concluded by granting in part and denying in part the defendant’s Motion to Dismiss. The motion was granted to the extent that claims accruing more than three years before June 13, 2023, are time-barred. In all other respects, including the application of the two-year statute of limitations, the motion was denied.
Schrag on Law 