Woodford v. HRG Management, LLC

Summary

The Connecticut Appellate Court affirmed the trial court’s judgment granting the defendants’ motion to strike Michelle Woodford’s putative class action claims concerning tip credits, wage-recordkeeping requirements, and nonservice work. The court adopted the reasoning of its companion decision, Farias v. Rodriguez, concluding that the cited regulation did not create a private cause of action for recordkeeping violations, that Public Act 22-134 governed the claims, and that its application did not violate due process.

Holdings

1. General Statutes § 31-68 does not provide a private cause of action for a recordkeeping violation under § 31-62-E3 of the 2015 wage regulations.
2. Public Act 22-134 did not impermissibly retroactively take away Woodford's cause of action, and claims filed after September 24, 2022, were required to be adjudicated solely under the version of § 31-60-2 effective September 24, 2020, and amendments thereto.
3. Applying P.A. 22-134 to Woodford's claims did not violate due process.

Questions Presented

1. Whether General Statutes § 31-68 provides a private cause of action for violations of the recordkeeping requirements in § 31-62-E3 of the 2015 Connecticut wage regulations.
2. Whether Public Act 22-134 retroactively deprived Woodford of a substantive cause of action under the Connecticut Minimum Wage Act.
3. Whether applying Public Act 22-134 to Woodford's claims violated due process.
4. Whether the trial court properly granted the defendants' motion to strike the claims alleging violations of the former wage regulations.

Disposition

affirmed