Brandi-Vanmeter v. MP2 Enterprises, LLC

CourtDistrict Court, D. Utah
DecidedJanuary 16, 2025
Docket4:23-cv-00081
StatusUnknown

This text of Brandi-Vanmeter v. MP2 Enterprises, LLC (Brandi-Vanmeter v. MP2 Enterprises, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brandi-Vanmeter v. MP2 Enterprises, LLC, (D. Utah 2025).

Opinion

THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

Rebecca Brandi-Vanmeter, MEMORANDUM DECISION AND Plaintiff, ORDER FOR PRECERTIFICATION DISCOVERY OF THE ARBITRATION v. AGREEMENTS

MP2 Enterprises, LLC; Bryant Peterson; Case No. 4:23-cv-00081-DN-PK Layne Peterson; Doe Corporation 1-10; John Doe 1-10, District Judge David Nuffer

Defendant.

Plaintiff Rebecca Brandi-Vanmeter filed a Motion1 that requests the certification of four Rule 23 subclasses of pizza delivery drivers that were allegedly being paid below minimum wage.2 Defendants filed a Response3 arguing that certification should be denied because of MP2 Enterprises’ practice of having employees sign binding arbitration agreements. Plaintiff filed a Reply4 in support of its Motion and in opposition to Defendants’ Response. Based on the parties’ filings and the evidence in the record, precertification discovery of MP2 Enterprises’ arbitration agreements is ordered.

1 Motion to Certify Class (“Plaintiff’s Motion”), docket no. 30, filed January 5, 2024. 2 The delivery drivers would be divided into four subclasses to represent the four states where the delivery drivers worked: Alaska, Arizona, Utah, and Nevada. Plaintiff’s Motion at 1. 3 Response to Motion to Certify Class (“Defendants’ Response”), docket no. 35, filed February 2, 2024. 4 Reply to Response to Motion (“Plaintiff’s Reply”), docket no. 38, filed March 4, 2024. BACKGROUND Defendants operate Pizza Hut locations in Alaska, Arizona, Utah, and Nevada.5 Plaintiff alleges that she and other similarly situated delivery drivers were paid under federal and state minimum wage rates because they were reimbursed below the IRS standard reimbursement rate for their delivery driver expenditures, such as gasoline, insurance, and automobile maintenance.6

On May 14, 2024, conditional certification of an FLSA Collective Action was granted and Defendants were ordered to provide Plaintiff with the contact information of potential opt-in plaintiffs.7 Plaintiff’s instant motion requests certification of four Rule 23 subclasses of current and former delivery drivers that worked in Alaska, Arizona, Utah, and Nevada.8 In response, Defendants argue Plaintiff’s Motion for Certification should be denied because all of its employees (except the named Plaintiff) signed arbitration agreements that require them to: (1) arbitrate claims they may have against MP2 Enterprises; and (2) assert claims individually and not through class actions.9 In support of this argument Defendants filed: (1) a sworn affidavit by

the manager of MP2 Enterprises, Bryant Peterson; and (2) an unsigned arbitration agreement, which is dated for October 2023. Mr. Peterson attests that the company’s policy for the last five years is for each new hire to sign an arbitration agreement that requires their employees to pursue claims individually through arbitration and not class actions.10 In her Reply, Plaintiff argues: (1)

5 Complaint ¶2 at 2, docket no. 1, filed September 27, 2023. 6 Complaint, ¶70, at 10. 7 Order Granting Conditional Certification of FLSA Collective Action, docket no. 39, filed May 15, 2024. 8 Plaintiff’s Motion at 1. 9 Defendants’ Response at 2. 10 Declaration of Bryant Peterson, Exhibit A, ¶8 at 2, docket no. 35, filed February 2, 2024. Defendants waived their right to raise arbitration agreements in this litigation;11 (2) Defendants have not established any standard business practice relating to arbitration agreements;12 and (3) the class should be certified on this motion and then decertified if discovery reveals the arbitration agreements.13 DISCUSSION

1. Defendants may assert the arbitration agreements as a defense to Plaintiff’s Motion for Certification Defendants argue that Plaintiff’s class action should not be certified because all of their delivery drivers signed arbitration agreements, with the exception of the named Plaintiff.14 In response, Plaintiff argues Defendants waived their right to raise the arbitration agreement as a defense because they did not assert the arbitration agreement in their Amended Answer.15 Defendants’ Amended Answer does not specifically assert the arbitration agreement as a defense, but the Amended Answer does state: “Mention the arbitration agreement.”16 It is apparent from this statement that Defendants intended to assert the arbitration agreements as a defense in their Amended Answer, but forgot to provide a more detailed defense by mistake. “The purpose of . . . pleading [an affirmative defense] is to give the opposing party notice of the [defense] and a chance to argue, if he can, why the imposition of [the defense] would be inappropriate.”17 “The best procedure is to plead an affirmative defense in an answer or amended

11 Defendants’ Response at 1-2. 12 Defendants’ Response at 2-4. 13 Defendants’ Response at 7-9. 14 Defendants’ Response at 2. 15 Plaintiffs’ Reply at 2 (“Here, Defendants did not raise arbitration in their Answer or Amended Answer, either as an affirmative defense or otherwise.”). 16 Amended Answer at 17, docket no. 28, filed December 29, 2023. 17 Ahmad v. Furlong, 435 F.3d 1196, 1201 (10th Cir. 2006) (alterations in original). answer.”18 However, even if “a party has not formally moved to amend its answer . . . a district court may allow the party to ‘constructively’ amend [its] answer, such as by raising an affirmative defense in a motion for summary judgment.”19 “Courts should consider several factors in determining whether to allow a party's constructive amendment.”20 The trial court’s “primary consideration is whether the opposing party will suffer prejudice.”21 Additionally,

“denial of a proposed amendment is appropriate if the amendment is an attempt to make a pleading a moving target or to salvage a lost case by untimely suggestion of new theories.”22 Courts may also deny a constructive amendment “on grounds such as undue delay, bad faith or dilatory motive.”23 Defendants may assert the arbitration agreements as a defense to Plaintiff’s Motion for Certification. Defendants did not waive their right to assert the arbitration agreements as a defense, and none of the other grounds for denial (i.e., prejudice, undue delay, bad faith, dilatory motive, or salvage a lost case) are present. 2. Plaintiff established a genuine dispute as to a material fact with regards to the arbitration agreements Defendants argue that their routine practice of having all of their employees sign arbitration agreements for the last five years shifted the burden to Plaintiff to prove a genuine dispute of material fact to prevent the application of the arbitration agreements.24 In Hancock v. AT&T, the Tenth Circuit analyzed whether the defendant’s filed declarations regarding the

18 Sky Harbor Air Serv., Inc. v. Reams, 491 F. App'x 875, 884 (10th Cir. 2012). 19 Sky Harbor Air Serv., Inc., 491 F. App'x at 884. 20 Sky Harbor Air Serv., Inc., 491 F. App'x at 884. 21 Sky Harbor Air Serv., Inc., 491 F. App'x at 884. 22 Sky Harbor Air Serv., Inc., 491 F. App'x at 884. 23 Sky Harbor Air Serv., Inc., 491 F. App'x at 884. 24 See Defendants’ Response at 4; Hancock v. Am. Tel. & Tel. Co., 701 F.3d 1248, 1264 (10th Cir. 2012). corporation’s standard practice of having their customers sign arbitration agreements was sufficient compel arbitration.25 “Under Rule 406, [e]vidence of . . . an organization's routine practice may be admitted to prove that on a particular occasion the . . . organization acted in accordance with the . . . routine practice.”26 If the parties disagree on the applicability of an arbitration agreement, a court may compel arbitration “if there are no genuine issues of material

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Related

Ahmad v. Furlong
435 F.3d 1196 (Tenth Circuit, 2006)
Sky Harbor Air Service, Inc. v. Reams
491 F. App'x 875 (Tenth Circuit, 2012)
Hancock v. American Telephone & Telegraph Co.
701 F.3d 1248 (Tenth Circuit, 2012)

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Brandi-Vanmeter v. MP2 Enterprises, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brandi-vanmeter-v-mp2-enterprises-llc-utd-2025.