Michael Carter and other plaintiffs sued the City of St. Louis in the United States District Court for the Eastern District of Missouri, raising claims under the Fair Labor Standards Act (FLSA), Missouri’s Notice of Reduction of Wages Law, Missouri’s Minimum Wage Law, the City Charter, the Equal Protection Clause, and for breach of contract. The City of St. Louis moved to dismiss plaintiffs’ claims under Rule 12(b)(6).
Factual Overview
Plaintiffs, who are Black heavy equipment operators employed by the City of St. Louis in its Refuse Division, alleged that they were denied overtime compensation and retaliated against for filing a lawsuit. Plaintiffs claimed that in early 2023, the City denied them wages, including overtime wages, for hours they worked. In February 2024, the City allegedly changed its overtime and wage policies to preclude plaintiffs from receiving overtime pay for additional routes unless their scheduled hourly shift had ended. Plaintiffs contended that this policy change was made without notice and in retaliation for their FLSA lawsuit filed in October 2023.
Legal Analysis
Overtime Compensation Claims (Counts I and IV): The court found that plaintiffs adequately alleged overtime compensation claims under the FLSA and Missouri’s Minimum Wage Law for hours worked in excess of their usual job requirements. However, the court dismissed the claims to the extent they sought overtime compensation for payloads when their workweeks did not exceed 40 hours.
FLSA Retaliation Claim (Count II): The court denied the City’s motion to dismiss the FLSA retaliation claim, finding that plaintiffs’ allegations were sufficient to survive dismissal at this stage.
Missouri Notice of Reduction of Wages Claim (Count III): The court denied the City’s motion to dismiss this claim, as plaintiffs alleged that the City is a corporation for purposes of the statute and the City did not provide authority supporting its position.
Equal Protection Claim (Count VI): The court dismissed the Equal Protection claim, finding that plaintiffs failed to allege sufficient facts to establish that they were treated dissimilarly from similarly situated white heavy equipment operators.
Breach of Contract (Count VII):The court dismissed the breach of contract claim, as plaintiffs admitted they had no implied contract with the City and did not allege that they were parties or third-party beneficiaries entitled to enforce the provisions of the collective bargaining agreement between the City and the union.
The court granted the City’s motion to dismiss Counts V, VI, and VII, granted in part and denied in part the motion as to Counts I and IV, and denied the motion in all other respects.
Schrag on Law 