AWK CONSULTING ENGINEERS, INC. v. PAYLOCITY CORPORATION

CourtDistrict Court, W.D. Pennsylvania
DecidedJanuary 31, 2025
Docket2:24-cv-00898
StatusUnknown

This text of AWK CONSULTING ENGINEERS, INC. v. PAYLOCITY CORPORATION (AWK CONSULTING ENGINEERS, INC. v. PAYLOCITY CORPORATION) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AWK CONSULTING ENGINEERS, INC. v. PAYLOCITY CORPORATION, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA AWK CONSULTING ENGINEERS, ) ) INC. ) 2:24-CV-898-NR ) Plaintiff, ) ) v. ) ) ) PAYLOCITY CORPORATION, ) ) Defendant. )

MEMORANDUM ORDER Plaintiff AWK Consulting Engineers, Inc. brings breach-of-contract and unjust-enrichment claims against Defendant Paylocity Corporation in connection with a contract for payroll administration services, alleging that Paylocity had a duty to detect an AWK employee’s fraudulent payroll activities. Paylocity now moves to dismiss the complaint for failure to state a claim. For the reasons below, the Court will grant Paylocity’s motion, and dismiss the complaint with prejudice. BACKGROUND Under the parties’ July 2018 contract, Paylocity provided AWK with payroll administration services. ECF 1-1, ¶ 8. There are several clauses in the contract that are relevant to this dispute. Under the “Confidentiality and Protection of Client Data” section: Paragraph 2 states: “Paylocity will maintain adequate security over CLIENT [i.e., AWK] information using commercially reasonable safeguards over the hardware, software, personnel and processes used to support the delivery of payroll and related services to the CLIENT . . . .” ECF 1-1, p. 31. Paragraph 3 states: “CLIENT will maintain adequate security over the hardware, personnel and processes used to access Paylocity’s software and services, including usernames and passwords used to access Paylocity’s software.” Id. Under the “Responsibilities” section: Paragraph 1 states: “Paylocity will use due care in processing CLIENT’s work, and shall be responsible for correcting errors which are caused by Paylocity equipment, processors, or employees in the course of their work.” Id. Paragraph 5 states: “CLIENT is solely responsible for the content and accuracy of all data input and then subsequently processed by Paylocity. CLIENT will submit to Paylocity its payroll and other data in a form, at a time and by the method specified by Paylocity. Because the accuracy of the payroll and other information is limited to the CLIENT’s data, Paylocity is not responsible for CLIENT errors, wage and hour violations, employment discrimination, garnishment calculations or other employment policies which may violate the law. It is the CLIENT’s responsibility to review the processed payroll and other information and to promptly identify any errors. If the data submitted to Paylocity is incorrect, incomplete, or not in proper form, then CLIENT agrees to pay Paylocity’s additional charges then in effect for the corrections to said data.” Id. After the parties entered into the contract, AWK hired an employee, Tracey Smith, who “suppl[ied] Paylocity with necessary data and documentation to process AWK’s payroll.” ECF 1-1, ¶ 12. But, in June 2022, Ms. Smith began to run payroll for herself “outside of the customary two times a month,” and at some point, was running payroll for herself multiple times in a single week. Id., ¶¶ 13-15. She did this by creating “two separate control numbers in the Paylocity system for herself in order to run multiple payrolls under the same social security number[.]” Id., ¶ 17. AWK didn’t discover Ms. Smith’s fraudulent conduct until May 2023. Id., ¶ 16. During this period, Ms. Smith processed payroll through Paylocity, embezzling $499,272.10. Id., ¶¶ 18-20. After AWK discovered the fraud, it sued Paylocity in state court for breach of contract and unjust enrichment, claiming that Paylocity “failed on multiple occasions” to detect Ms. Smith’s “frequent, ongoing, numerous, and unauthorized fraudulent transactions despite being contractually obligated to do so.” Id., ¶ 32. According to AWK, this constituted a breach of Paylocity’s duties under the contract; and, alternatively, a form of unjust enrichment. Paylocity removed the action to federal court, and then moved to dismiss the complaint on the ground that it fails to state claims for breach of contract or unjust enrichment. ECF 1; ECF 8. The motion is now ready for disposition.1 DISCUSSION & ANALYSIS2 I. AWK’s contract claim fails because there was no contractual duty for Paylocity to detect and prevent the fraud. The contract here is governed by Illinois law, and so the Court turns to Illinois law to analyze AWK’s contract claim.3 “In Illinois, in order to plead a cause of action

1 In opposing Paylocity’s motion, AWK argues that the motion should be denied because Paylocity filed it without first meeting and conferring with AWK, as required by the Court’s Practices and Procedures. ECF 14, p. 2. However, after the motion was fully briefed, the Court ordered the parties to meet and confer on the issues raised in the motion. ECF 20. The parties then did so, and notified the Court that they did not reach any agreement on the claims in this case that would narrow the motion or lead to any sort of curative amendment of the complaint. ECF 21. As such, the Court will decide the motion on the merits.

2 “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (cleaned up). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. Any reasonable inferences should be considered in the light most favorable to the plaintiff. See Lula v. Network Appliance, 255 F. App’x 610, 611 (3d Cir. 2007) (citing Rocks v. City of Phila., 868 F.2d 644, 645 (3d Cir. 1989)). 3 The contract states: “This Agreement shall be construed according to the laws of the State of Illinois and constitutes the entire Agreement between the parties.” ECF 1- 1, p. 33. Because this is a diversity jurisdiction case, the Court must apply the choice of law rules of the forum state. Cook v. Gen. Nutrition Corp., 749 F. App’x 126, 129 for breach of contract, a plaintiff must allege: (1) the existence of a valid and enforceable contract; (2) substantial performance by the plaintiff; (3) a breach by the defendant; and (4) resultant damages. Only a duty imposed by the terms of a contract can give rise to a breach.” TAS Distrib. Co. v. Cummins Engine Co., 491 F.3d 625, 631 (7th Cir. 2007) (cleaned up). AWK alleges that Paylocity breached the contract in three ways: (1) “By failing to maintain adequate security over AWK’s information using commercially reasonable safeguards;” (2) “By failing to use due care in processing AWK’s work;” and (3) “By not being responsible for correcting the obvious errors regarding AWK’s submitted information for processing.” ECF 1-1, ¶ 35. Paylocity, in response, argues that the party that was contractually bound to monitor, detect, and prevent Ms. Smith’s fraudulent conduct was AWK, not Paylocity. ECF 9, p. 2. “Under Illinois’s four corners rule, if a written agreement is unambiguous, then the scope of the parties’ obligations must be determined from the contract language without reference to extrinsic evidence.” SMS Demag Aktiengesellschaft v. Material Scis. Corp., 565 F.3d 365, 372 (7th Cir. 2009) (cleaned up); see Kallman v. Radioshack Corp., 315 F.3d 731, 735 (7th Cir. 2002) (noting that interpretation of the terms of an unambiguous contract is “traditionally a question of law”); Palda v. Gen. Dynamics Corp., 47 F.3d 872, 876 (7th Cir.

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AWK CONSULTING ENGINEERS, INC. v. PAYLOCITY CORPORATION, Counsel Stack Legal Research, https://law.counselstack.com/opinion/awk-consulting-engineers-inc-v-paylocity-corporation-pawd-2025.