Plaintiff Cecilia Castello sued defendants Sudora, LLC and Robert Meyer, Jr. in the United States District Court for the Eastern District of Missouri, raising claims under the Fair Labor Standards Act and Missouri Minimum Wage Law for unpaid wages. Defendants moved to dismiss the action under Federal Rule of Civil Procedure 12(b)(1), arguing the court lacked subject matter jurisdiction.
Factual Overview
Plaintiff Castello and defendant Meyer married in 2006. Meyer owned and operated Sudora, LLC, an information technology services company. From 2006 until 2022, Castello worked as an office and payroll manager for Sudora but allegedly received no compensation for her work during this entire period. In September 2022, Meyer initiated divorce proceedings against Castello and terminated her employment shortly thereafter due to their deteriorated personal relationship. Castello then filed this federal lawsuit seeking unpaid wages under federal and state law. Defendants moved to dismiss, arguing that the court lacked jurisdiction under the domestic relations exception and that the claims were improperly split from the divorce proceeding. Defendants also contended that claims for work performed before February 8, 2024, were time-barred by the applicable three-year statutes of limitations.
Legal Analysis
Domestic Relations Exception: The court rejected defendants’ argument that the domestic relations exception barred jurisdiction. The court explained that this exception only applies to diversity jurisdiction cases, not federal question cases like this one arising under the FLSA. Even if the exception could apply to federal question cases, the court found that this wage dispute was not inextricably intertwined with the state divorce proceeding because it did not require the court to issue or modify any divorce, alimony, or child custody decree.
Improper Claim Splitting: The court also rejected defendants’ claim splitting argument. While acknowledging some overlap between the federal wage claims and state divorce proceeding, the court found they did not arise from the same nucleus of operative facts. The wage claims required proof of work performed and lack of compensation, while the divorce proceeding focused on dissolving the marriage and distributing marital property based on irreconcilable differences. The court determined these were different wrongs seeking different remedies.
The court denied defendants’ motion to dismiss, allowing plaintiff’s FLSA and MMWL claims to proceed.
Schrag on Law 