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Short-Irons v. Catham Acres Healthcare Group, Inc.

United States District Court, E.D. Pennsylvania

August 20, 2019



          Gene E.K. Pratter United States District Judge.

         August 16, 2019 Shamera Short-Irons alleges that, while employed by Catham Acres Healthcare Group, she would often work through her 30-minute unpaid meal break. She claims that when she reported to her supervisor that Catham Acres employees were not being paid for some of their work day, she was fired. She brings this suit for retaliation under the Fair Labor Standards Act. Catham Acres moves to dismiss. For reasons set forth below, the Court denies the motion in its entirety.


         Shamera Short-Irons worked for Catham Acres Healthcare Group for just under three years. Catham Acres' policies and procedures stated that employees would receive an unpaid 30-minute meal break for each shift worked.[1] According to Ms. Short-Irons, she regularly worked through her meal break and was not compensated for those 30 minutes of each day. Ms. Short-Irons reported to Catham Acres staff and supervisors that she was working through her meal break without pay. Eventually, Ms. Short-Irons also confronted her direct supervisor, who allegedly chastised Ms. Short-Irons and told her to go back to work. Shortly after this interaction, Catham Acres fired Ms. Short-Irons.

         Legal Standard

         Although "a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiffs obligation to provide the 'grounds' of his 'entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations omitted). To survive a Rule 12(b)(6) motion, therefore, the plaintiff must plead "factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Specifically, "[f]actual allegations must be enough to raise a right to relief above the speculative level." Twombly, 550 U.S. at 555. The question is not whether the plaintiff "will ultimately prevail. . . but whether [the] complaint [is] sufficient to cross the federal court's threshold." Skinner v. Switzer, 562 U.S. 521, 530 (2011) (citation and quotation omitted). Thus, assessing the sufficiency of a complaint is "a context-dependent exercise" because "[s]ome claims require more factual explication than others to state a plausible claim for relief." W. Pa. Allegheny Health Sys., Inc. v. UPMC, 627 F.3d 85, 98 (3d Cir. 2010) (citations omitted).

         In evaluating the sufficiency of a complaint, the Court adheres to certain accepted benchmarks. For one, the Court "must consider only those facts alleged in the complaint and accept all of the allegations as true." ALA, Inc. v. CCAIR, Inc., 29 F.3d 855, 859 (3d Cir. 1994) (citation omitted); see also Twombly, 550 U.S. at 555 (stating that courts must "assum[e] that all the allegations in the complaint are true (even if doubtful in fact)"). The Court must accept as true all reasonable inferences emanating from the allegations and view those facts and inferences in the light most favorable to the nonmoving party. Rocks v. City of Phila., 868 F.2d 644, 645 (3d Cir. 1989).

         That admonition does not demand that the Court ignore or discount reality. The Court "need not accept as true unsupported conclusions and unwarranted inferences," Doug Grant, Inc. v. Greate Bay Casino Corp., 232 F.3d 173, 183-84 (3d Cir. 2000) (citations and quotation omitted), and "the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice." Iqbal, 556 U.S. at 678 (citation omitted). If a claim "is vulnerable to 12(b)(6) dismissal, a district court must permit a curative amendment, unless an amendment would be inequitable or futile." Phillips v. Cty. of Allegheny, 515 F.3d 224, 236 (3d Cir. 2008) (citation omitted).


         Catham Acres makes two arguments in favor of dismissal: (1) Ms. Short-Irons failed to exhaust administrative remedies, and (2) the complaint does not contain adequate details to state a claim. The Court denies the motion to dismiss, because the FLSA anti-retaliation provision does not include an exhaustion requirement and because the complaint adequately alleges a prima facie case for retaliation.

         I. Exhaustion

         Both precedent and the FLSA's plain text show that the FLSA does not impose an administrative exhaustion requirement in retaliation actions. The FLSA anti-retaliation provision[2]reads:

[I]t shall be unlawful for any person ... (3) to discharge or in any other manner discriminate against any employee because such employee has filed any complaint or instituted or caused to be instituted any proceeding under or related to this chapter, or has testified or is about to testify in any such ...

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