Aneiros v. VIORMAR TRADING CORPORATION, N.V.

CourtDistrict Court, S.D. Florida
DecidedSeptember 6, 2024
Docket1:24-cv-20772
StatusUnknown

This text of Aneiros v. VIORMAR TRADING CORPORATION, N.V. (Aneiros v. VIORMAR TRADING CORPORATION, N.V.) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aneiros v. VIORMAR TRADING CORPORATION, N.V., (S.D. Fla. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:24-cv-20772-GAYLES/LOUIS

DENNIS ANEIROS

Plaintiff,

v.

VIORMAR TRADING CORPORATION, N.V., and ORLANDO A. FERNANDEZ,

Defendants. ________________________________________/

ORDER

THIS CAUSE comes before the Court upon Viormar Trading Corporation, N.V. (“Viormar”) and Orlando A. Fernandez’s (“Fernandez”) (collectively “Defendants”) Joint Motion to Dismiss Plaintiff’s Amended Complaint (the “Motion”). [ECF No. 16]. The Court has reviewed the Motion and the record and is otherwise fully advised. For the following reasons, the Motion is GRANTED IN PART. BACKGROUND1 In 2010, Plaintiff Dennis Aneiros (“Plaintiff”) was living out of his car near one of Defendants’ properties. Fernandez’s father, on behalf of Viormar, approached Plaintiff and offered Plaintiff an opportunity to reside in one of Viormar’s offices in exchange for work.2 Plaintiff accepted. Plaintiff’s duties included cleaning, repairing, renovating, and collecting rent for Defendants’ commercial properties. Although Plaintiff worked approximately 40 hours per week,

1 As the Court proceeds on a motion to dismiss, it accepts the allegations in the Amended Complaint as true. See Brooks v. Blue Cross & Blue Shield of Fla., Inc., 116 F.3d 1364, 1369 (11th Cir. 1997) (per curiam). 2 According to Complaint, Fernandez took over the “scheme” after his father died. Defendants did not pay him an hourly wage; rather, Plaintiff’s compensation was free lodging.3 Id. For the next fourteen years, Plaintiff continued to work for Defendants. Plaintiff contends that Defendants threatened him with “serious harm” by stating that if he stopped working, he would not be permitted to reside at their property. [Id. at 41].

On April 9, 2024, Plaintiff filed an Amended Complaint against Defendants, alleging violations of the Fair Labor Standards Act, 29 U.S.C. § 201, et seq. (the “FLSA”) (Count I); the Florida Minimum Wage Act, Fla. Stat. § 448.110, et seq. (the “FMWA”) (Count II); and the Trafficking Victims Protection Act, 18 U.S.C. § 1589, (the “TVPA”) (Count III). [ECF No. 13]. Defendants now move to dismiss Counts II and III of the Amended Complaint, arguing (1) any damages under the TVPA for work Plaintiff performed more than ten years ago are time barred, (2) Plaintiff failed to plead his TVPA claim with the requisite particularity, and (3) Plaintiff’s FMWA claims stemming from work performed more than two years before the filing of this action are time barred.4 [ECF No. 16]. LEGAL STANDARD

To survive a motion to dismiss brought pursuant to Federal Rule of Civil Procedure 12(b)(6), a claim “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face,’” meaning that it must contain “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) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). While a court must accept well-pleaded factual allegations as true, “conclusory allegations . . . are not entitled to an assumption of truth—legal conclusions must be supported by factual allegations.”

3 Plaintiff lived in one of Defendants’ offices. The room contained a sofa bed and bathroom. It did not have a kitchen or shower. Plaintiff alleges the rental value of the office is less than minimum wage. [ECF No. 13 ¶ 20]. 4 In paragraph 10 of the Motion, Defendants state that “Count I should be dismissed.” This appears to be a scrivener’s error. Randall v. Scott, 610 F.3d 701, 709–10 (11th Cir. 2010). “[T]he pleadings are construed broadly,” Levine v. World Fin. Network Nat’l Bank, 437 F.3d 1118, 1120 (11th Cir. 2006), and the allegations in the complaint are viewed in the light most favorable to the plaintiff. Bishop v. Ross Earle & Bonan, P.A., 817 F.3d 1268, 1270 (11th Cir. 2016). “Threadbare recitals of the elements

of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. Therefore, a complaint that merely presents “labels and conclusions or a formulaic recitation of the elements of a cause of action” will not survive dismissal. Id. (internal quotation omitted). DISCUSSION I. Count II of Plaintiff’s Amended Complaint is a Shotgun Pleading A complaint that violates Federal Rule of Civil Procedure 8 is “often disparagingly referred to as [a] shotgun pleading[].” Weiland v. Palm Beach Cty. Sheriff’s Off., 792 F.3d 1313, 1320 (11th Cir. 2015) (internal quotation marks omitted). The Eleventh Circuit generally considers a complaint to be a shotgun pleading if it (1) “contain[s] multiple counts where each count adopts the allegations of all preceding counts, causing each successive count to carry all that came before

and the last count to be a combination of the entire complaint,” id. at 1321; (2) is “replete with conclusory, vague, and immaterial facts not obviously connected to any particular cause of action,” id. at 1322; (3) fails to “separate[] into a different count each cause of action or claim for relief,” id. at 1323; or (4) “assert[s] multiple claims against multiple defendants without specifying which of the defendants are responsible for which acts or omissions, or which of the defendants the claim is brought against.” Id. Shotgun pleadings “fail to give the defendants adequate notice of the claims against them and the grounds upon which each claim rests . . . and waste scarce judicial resources, inexorably broaden the scope of discovery, wreak havoc on appellate court dockets, and undermine the public’s respect for the courts.” Arrington v. Green, 757 F. App’x 796, 797 (11th Cir. 2018) (per curiam) (citations omitted). Although not raised in the Motion, Count II must be dismissed because it violates the first Weiland category by adopting the allegations of the preceding count. See 792 F.3d at 1321.

Specifically, Count II reincorporates paragraphs one through nineteen of the Amended Complaint, which includes allegations within Count I. [ECF No. 13]. Based on this pleading deficiency, Count II shall be dismissed without prejudice.5 II. The TVPA Claim The TVPA prohibits knowingly provid[ing] or obtain[ing] the labor or services of a person by any one of, or by any combination of, the following means—

(1) by means of force, threats of force, physical restraint, or threats of physical restraint to that person or any person;

(2) by means of serious harm or threats of serious harm to that person or another person;

(3) by means of the abuse or threatened abuse of law or legal process; or

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Related

Stephen G. Levine v. World Financial Network Nat'l
437 F.3d 1118 (Eleventh Circuit, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Randall v. Scott
610 F.3d 701 (Eleventh Circuit, 2010)
Connie Bishop v. Ross Earle & Bonan, P.A.
817 F.3d 1268 (Eleventh Circuit, 2016)
Brooks v. Blue Cross & Blue Shield of Florida, Inc.
116 F.3d 1364 (Eleventh Circuit, 1997)

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