Plaintiffs Chrystal LaCour and Madysen Sitton sued Defendant EthruE-001, LLC in the United States District Court for the Eastern District of Missouri, raising claims of failure to pay minimum wage and overtime in violation of the Fair Labor Standards Act (FLSA) and Missouri Minimum Wage Law (MMWL), as well as claims under the Missouri Unpaid Wage Law (MUWL) and Missouri common law. EthruE-001 moved to dismiss Counts I-IV and VI under Rule 12(b)(6) for failure to state a claim and moved to abstain from exercising jurisdiction over Count V pursuant to 28 U.S.C. § 1367(c).
Factual Overview
LaCour and Sitton were employed by EthruE-001 as maid associates from July 2023 through October 2023. They allege that EthruE-001 failed to pay minimum wage for all hours worked and overtime for hours worked over 40 per week by only paying them for the “allocated time” for each job, regardless of the actual time spent cleaning homes. Plaintiffs also allege that EthruE-001 arbitrarily reduced their wages without providing a 30-day notice.
Legal Analysis
Failure to State a Claim for Minimum Wage and Overtime Violations: The court found that Plaintiffs failed to sufficiently allege claims for minimum wage and overtime violations under the FLSA and MMWL. The court determined that payment by job allocation, as described in the Complaint, is lawful under both the FLSA and MMWL if employees are paid at least the applicable minimum wage for all hours worked. The court concluded that Plaintiffs did not provide sufficient factual allegations to show there was at least one workweek when they were not paid the applicable minimum wage or overtime for hours worked over 40.
Supplemental Jurisdiction over State-Law Claims: The court declined to exercise supplemental jurisdiction over the remaining state-law claims in Count V, finding that these claims are best suited for resolution by a Missouri state court. The court dismissed Count V without prejudice pursuant to 28 U.S.C. § 1367(c)(3).
The court granted EthruE-001’s Motion to Dismiss, dismissing Counts I-IV with prejudice and Count VI without prejudice, and granted EthruE-001’s Motion to Abstain from exercising jurisdiction over Count V, dismissing it without prejudice.
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