Francisco Alejandro Zuniga Coronado v. S&J Carpeting, LLC, et al.

Summary

The United States District Court for the Western District of Michigan denies without prejudice Plaintiff Francisco Alejandro Zuniga Coronado’s motion for default judgment in an employment action against S&J Carpeting, LLC and Jonathan Sanchez Cervantes. The court concludes that Coronado sufficiently alleged FLSA overtime and unpaid-wage claims but did not establish damages with reasonable certainty, and that he failed to state claims based on delayed wages and retaliation. The court also determines that IWOWA does not provide an overtime claim under the circumstances described.

Holdings

1. Coronado sufficiently alleged an FLSA unpaid-overtime claim because he alleged an employment relationship, engagement in interstate commerce, more than forty hours of work per week, and nonpayment of overtime. However, default judgment could not be entered because his damages calculation was not established with reasonable certainty.
2. Coronado could not pursue an IWOWA overtime claim because his employer was subject to the FLSA and the applicable version of IWOWA excluded its overtime provisions for employers covered by the FLSA.
3. Coronado did not state an FLSA minimum-wage claim based on delayed payment because he did not provide enough information to determine whether the replacement payments were untimely. The court did not resolve whether IWOWA independently permits recovery for late-paid minimum wages.
4. Coronado sufficiently alleged an FLSA and IWOWA minimum-wage claim for one week of unpaid work, but he did not establish damages with reasonable certainty.
5. Coronado did not state an FLSA retaliation claim because he failed to allege facts supporting a reasonable inference that his termination was caused by his wage complaint.

Questions Presented

1. Whether Coronado established a sufficient basis for default judgment on his FLSA and IWOWA unpaid-overtime claims.
2. Whether Coronado stated viable FLSA and IWOWA minimum-wage claims based on delayed and unpaid wages.
3. Whether Coronado stated an FLSA retaliation claim based on his termination after complaining about unpaid wages.
4. Whether Coronado established the amount of damages with reasonable certainty for the claims that were sufficiently pleaded.

Disposition

other