Arkansas Home-Based Services Association, Inc. v. Pinnacle In Home Care, LLC

CourtDistrict Court, W.D. Arkansas
DecidedSeptember 30, 2024
Docket5:23-cv-05206
StatusUnknown

This text of Arkansas Home-Based Services Association, Inc. v. Pinnacle In Home Care, LLC (Arkansas Home-Based Services Association, Inc. v. Pinnacle In Home Care, LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arkansas Home-Based Services Association, Inc. v. Pinnacle In Home Care, LLC, (W.D. Ark. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS FAYETTEVILLE DIVISION

ARKANSAS HOME-BASED SERVICES ASSOCIATION, INC. PLAINTIFF

V. CASE NO. 5:23-CV-5206

PINNACLE IN HOME CARE, LLC; VICTORIA WILLIAMS; and LAWRENCE WILLIAMS DEFENDANTS

OPINION AND ORDER

Now before the Court are Defendants Pinnacle In Home Care, LLC, Victoria Williams, and Lawrence Williams’s Motion to Dismiss (Doc. 10) and Plaintiff Arkansas Home-Based Services Association, Inc.’s Motion to Amend Complaint (Doc. 29). Both motions are fully briefed and ripe for review. For the reasons stated herein, the Motion to Dismiss is GRANTED and the Motion to Amend is DENIED. Arkansas Home-Based Services Association (“AHB”) is an Arkansas association that is comprised of member businesses that provide home-based care to aging and disabled persons. (Doc. 2, ¶ 2). Pinnacle is a separate home-based care provider in Arkansas that competes with AHB’s members. Id. at ¶ 11. Pinnacle is owned by Victoria and Lawrence Williams, both of whom are Arkansas residents.1 Id. at ¶¶ 12-13. AHB brings this suit against Pinnacle alleging, in short, that Pinnacle misclassifies its employees as independent contractors in violation of the Arkansas Minimum Wage Act and the Fair Labor Standards Act (“FLSA”), creating an unfairly competitive market for AHB’s members. AHB alleges that, through this misclassification, Pinnacle “falsely

1 The Court will collectively refer to the three defendants as “Pinnacle.” augment[s] take-home pay given the absence of mandatory payroll withholdings,” which allegedly requires AHB’s members to pay higher wages to compete with Pinnacle. Id. at ¶ 68. Additionally, AHB alleges that Pinnacle’s misclassification allows it to evade paying certain taxes and benefits, so it can charge its clients less and dominate a

disproportionate share of the home-based-services market as compared to law-abiding companies. Id. at ¶ 65. AHB brings claims under the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1961 et seq.; the Arkansas Unfair Practices Act (“AUPA”), Arkansas Code § 4-75-201 et seq.; the tort of unfair competition; and the Arkansas Declaratory Judgment Act (“ADJA”), Arkansas Code § 16-111-101 et seq. AHB seeks a declaratory judgment “establishing that AMWA and FLSA require Pinnacle to classify and pay its care professionals as employees who are entitled to minimum wage and overtime.” (Doc. 2, ¶ 180). The Complaint also requests preliminary and permanent injunctions to the same effect, as well as monetary damages. See id. at ¶ 113 (claiming entitlement to relief under

18 U.S.C. § 1964(c) which provides treble damages for RICO violations). Pinnacle moves to dismiss under Federal Rule of Civil Procedure 12(b)(1) for lack of Article III standing, or in the alternative, under Rule 12(b)(6) for failure to state a claim. Ultimately, the Court finds that AHB fails to sufficiently plead Article III standing. Further, even if there were constitutional standing, AHB lacks statutory standing to bring a RICO claim, in which case the Court would decline to exercise supplementary jurisdiction over the remaining state law claims. Lastly, regarding the Motion for Leave to Amend, AHB’s proposed amended complaint would not withstand dismissal under Rule 12 and is, therefore, futile. I. MOTION TO DISMISS (DOC. 10) A. Constitutional Standing Under Article III To survive a motion to dismiss under Rule 12(b)(1) for lack of standing, a plaintiff “must allege sufficient factual matter, accepted as true, to support a reasonable and

plausible inference that [it] satisfies the elements of Article III standing.” See Hawse v. Page, 7 F.4th 685, 688-89 (8th Cir. 2021) (citations omitted). That is, a plaintiff must allege facts demonstrating: (1) it has “suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.” Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016) (quoting Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992)). In addition to being actual or imminent, an injury in fact must be concrete and particularized, meaning the injury is not abstract or merely a “generalized grievance.” FDA v. All. for Hippocratic Med., 602 U.S. 367, 381 (2024) (citing TransUnion LLC v. Ramirez, 594 U.S. 413, 424 (2021) and

Lujan, 504 U.S. at 560). “Article III grants federal courts the power to redress harms that defendants cause plaintiffs, not a freewheeling power to hold defendants accountable for legal infractions.” TransUnion, 594 U.S. at 427 (quotation marks and citation omitted). An association may bring a claim based on its own standing or on behalf of its members—i.e., “associational” or “representational” standing—provided certain additional requisites are met. AHB makes explicit “the only claim for which [it] asserts representational standing is its RICO claim.” (Doc. 20, p. 24 n.3). Accordingly, the Court will analyze AHB’s standing to bring the AUPA, tort, and ADJA claims on its own behalf, then it will turn to AHB’s associational standing to bring the RICO claim. A. AHB’s Standing to Bring AUPA, Tort, and ADJA Claims AHB lacks standing to bring these claims on its own behalf because it fails to allege

any injury in fact that the association itself has suffered. For both its AUPA and ADJA claims, AHB relies heavily on the argument that the Arkansas legislature has provided it a right of action. (Doc. 20, pp. 15-16). Even granting that to be true, it is insufficient to overcome AHB’s failure to plead injury in fact, which is “a hard floor of Article III jurisdiction that cannot be removed by statute.” See Summers v. Earth Island Inst., 555 U.S. 488, 497 (2009); Spokeo, 578 U.S. at 341; see also Lujan, 504 U.S. at 580-81 (Kennedy, J., concurring in part and concurring in judgment). The legislature’s “creation of a statutory prohibition or obligation and a cause of action does not relieve courts of their responsibility to independently decide whether a plaintiff has suffered a concrete harm under Article

III . . . .” TransUnion, 594 U.S. at 426. Therefore, this fails to support standing. Although AHB argues in its brief that it has been harmed by Pinnacle’s actions, the Complaint makes no factual allegation to this effect. (Doc. 20, pp. 15-16). Rather, AHB makes only conclusory allegations that Pinnacle’s actions injured AHB’s members and competition more broadly. See, e.g., Doc. 2, ¶¶ 156, 157, 162, 163. The same is true for AHB’s tort claim, which makes no allegation as to how AHB has suffered harm. See Doc. 2, p. 39. For its ADJA claim, AHB argues that its interests are adverse to Pinnacle because AHB has “a legal interest in the determination of whether Pinnacle is unfairly competing in the same market as its members.” (Doc. 20, p. 17). But again, the Complaint alleges no facts as to how AHB has been injured. See Doc. 2, ¶¶ 175-81. As Pinnacle notes in its Reply, if such claims were allowed to proceed, every Arkansas business will be empowered to identify laws its rivals may be breaking and sue them in federal court because their alleged lack of compliance isn’t “fair.” If a retailer believes its competitor is violating OSHA, bring an unfair practices claim; if a poultry supplier thinks its competitors aren’t complying with USDA regulations, bring an unfair practices claim.

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Bluebook (online)
Arkansas Home-Based Services Association, Inc. v. Pinnacle In Home Care, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arkansas-home-based-services-association-inc-v-pinnacle-in-home-care-arwd-2024.