Maria Moreno v. Sonic Drive-In; Brad Stephens; and John Does I–X

Summary

The United States District Court for the District of Utah ruled on Defendants’ renewed motion to dismiss Maria Moreno’s employment-related claims. The court allowed Moreno’s Title VII discrimination and retaliation claims, UADA claim, FLSA claim, Utah Payment of Wages Act claim, and implied-covenant claim to proceed, but dismissed her ADEA and wrongful-termination claims. The decision applies Federal Rule of Civil Procedure 12(b)(6) pleading standards and was issued per curiam on February 9, 2026.

Holdings

1. Moreno plausibly alleged a Title VII employment-discrimination claim because she alleged protected-class status, termination, discriminatory comments and treatment toward Hispanic employees, pretextual reasons for termination, and temporal circumstances supporting an inference of discriminatory motive.
2. Moreno plausibly alleged Title VII retaliation because she alleged protected opposition, a materially adverse action, and a causal connection supported by detailed complaints and close temporal proximity between the complaints and her termination.
3. Moreno's UADA claim plausibly survived dismissal because UADA claims are analyzed under the same standards as Title VII claims, and her Title VII claims were adequately pleaded.
4. Moreno plausibly alleged an FLSA overtime claim by alleging that she regularly worked more than forty hours per week and was not paid overtime for that work.
5. Moreno failed to plausibly plead an ADEA claim because the amended complaint did not clearly assert such a claim and did not allege that she was treated less favorably than persons outside the ADEA-protected class.
6. Moreno failed to plausibly plead a Utah public-policy wrongful-termination claim because she did not adequately support with legal authority her contention that her internal complaints about wage and discrimination violations implicated a clear and substantial public policy.
7. The Utah Payment of Wages Act and implied covenant of good faith and fair dealing claims survived dismissal because defendants did not meaningfully address them and alternative pleading is permissible.

Questions Presented

1. Whether Moreno plausibly alleged Title VII discrimination based on national origin or sex.
2. Whether Moreno plausibly alleged Title VII retaliation based on her complaints about discriminatory treatment and allegedly unlawful pay practices.
3. Whether Moreno plausibly alleged a Utah Antidiscrimination Act claim.
4. Whether Moreno plausibly alleged an FLSA overtime claim.
5. Whether Moreno adequately pleaded an ADEA age-discrimination claim.
6. Whether Moreno adequately pleaded a Utah common-law wrongful-termination claim.
7. Whether Moreno's Utah Payment of Wages Act and implied-covenant claims could proceed as alternative claims when defendants did not meaningfully address them.

Disposition

other