Cross v. St. Clair County Emergency Management Administration

CourtDistrict Court, S.D. Illinois
DecidedJanuary 16, 2024
Docket3:23-cv-02594
StatusUnknown

This text of Cross v. St. Clair County Emergency Management Administration (Cross v. St. Clair County Emergency Management Administration) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cross v. St. Clair County Emergency Management Administration, (S.D. Ill. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

CANDIS CROSS and TINA JOAQUIN,

Plaintiff,

v. Case No. 23-cv-2594-JPG

ST. CLAIR COUNTY,

Defendant.

MEMORANDUM AND ORDER This matter comes before the Court on the motion of defendant St. Clair County, Illinois, to dismiss the Second Amended Complaint filed by plaintiffs Candis Cross and Tina Joaquin pursuant to Federal Rules of Civil Procedure 12(b)(6) or, in the alternative, for a more definite statement pursuant to Rule 12(e) (Doc. 32). Cross and Joaquin have responded to the motion (Doc. 34). The Court will deny the motion because the plaintiffs’ Second Amended Complaint pleads sufficient facts to plausibly suggest they have a right to relief from the County. I. Background Cross and Joaquin are employees of the St. Clair County Emergency Management Administration (“EMA”), a subdivision of the County. In the Second Amended Complaint (Doc. 29), they assert that part of their jobs required being on-call outside of normal business hours, which in turn resulted in their working additional hours beyond their normal forty-hour work week. They were paid one and one-half times their normal hourly rate for this overtime (“overtime premium”). At the beginning of January 2022, the County gave them a raise but stopped paying them the overtime premium for overtime hours. The County investigated and determined that the failure to pay the overtime premium was in error and resumed the overtime premium in February 2023. It did not, however, go back and pay the overtime premiums the plaintiffs had earned between January 2022 and February 2023.1 The plaintiffs sue the County because they believe the alleged failure to pay overtime for the period between January 2022 and February 2023 violates § 7(a)(1) of the Fair Labor Standards Act, 29 U.S.C. § 207(a)(1) (Count I), and § 4a(1) of the Illinois Minimum Wage Law, 820 ILCS 105/1 et seq. (Count II). The County asks for dismissal on the grounds that the

plaintiffs fail to plausibly state a claim for relief or, in the alternative, to make the plaintiffs state additional facts such as the specific timeframe of their unpaid overtime work, the amount of pay they claim they are due, and who the plaintiffs communicated with about the situation. II. Applicable Standards When considering a Rule 12(b)(6) motion to dismiss, the Court accepts as true all allegations in the complaint. Erickson v. Pardus, 551 U.S. 89, 94 (2007) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). To avoid dismissal under Rule 12(b)(6) for failure to state a claim, a complaint must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). This requirement is satisfied if the

complaint (1) describes the claim in sufficient detail to give the defendant fair notice of what the claim is and the grounds upon which it rests and (2) plausibly suggests that the plaintiff has a right to relief above a speculative level. Bell Atl., 550 U.S. at 555; see Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); see Kaminski v. Elite Staffing, Inc., 23 F.4th 774, 776 (7th Cir. 2022); EEOC v. Concentra Health Servs., 496 F.3d 773, 776 (7th Cir. 2007). “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.” Iqbal, 556 U.S. at 678 (citing

1 It is unclear whether the plaintiffs were not paid at all for their overtime work or whether they were paid their regular pay for those hours. The Court will require the plaintiffs to clarify this detail. Bell Atl., 550 U.S. at 556). “Determining whether a complaint states a plausible claim for relief will . . . be a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 679. In Bell Atlantic, the Supreme Court rejected the more expansive interpretation of Rule 8(a)(2) that “a complaint should not be dismissed for failure to state a claim unless it appears

beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief,” Conley v. Gibson, 355 U.S. 41, 45-46 (1957). Bell Atl., 550 U.S. at 561-63; Concentra Health Servs., 496 F.3d at 777. Now “it is not enough for a complaint to avoid foreclosing possible bases for relief; it must actually suggest that the plaintiff has a right to relief . . . by providing allegations that ‘raise a right to relief above the speculative level.’” Concentra Health Servs., 496 F.3d at 777 (quoting Bell Atl., 550 U.S. at 555). Nevertheless, Bell Atlantic did not do away with the liberal federal notice pleading standard. Airborne Beepers & Video, Inc. v. AT&T Mobility LLC, 499 F.3d 663, 667 (7th Cir. 2007). A complaint still need not contain detailed factual allegations. Bell Atl., 550 U.S. at 555.

Nevertheless, it must contain “more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Bell Atl., 550 U.S. at 555. If the factual detail of a complaint is “so sketchy that the complaint does not provide the type of notice of the claim to which the defendant is entitled under Rule 8,” it is subject to dismissal. Airborne Beepers, 499 F.3d at 667; see, e.g., Kaminski, 8 F.4th at 776-77. Where a defendant thinks a complaint is too vague or ambiguous for it to respond intelligently or for the Court to handle the litigation effectively, it may move for a more definite statement under Federal Rule of Civil Procedure 12(e); see Shuhaiber v. Ill. Dep't of Corr., 980 F.3d 1167, 1170 (7th Cir. 2020). Under that rule, it is within the Court’s discretion whether to order a party to provide a more definite statement, although such motions are not favored in view of the liberal federal pleading standards discussed above. Lucas v. Blankenship Constr. Co., No. 22-cv-56-JPG, 2023 WL 7300216, * 1 (S.D. Ill. Nov. 6, 2023). More definite statements are most often reserved for complaints that are unintelligible, not those that simply lack detail. See, e.g., American Nurses’ Ass’n v. State of Ill., 783 F.2d 716, 726 (7th Cir. 1986); Stepp v. Covance

Cent. Lab. Servs., Inc., 931 F.3d 632, 634 (7th Cir. 2019) (noting that if a complaint were indecipherable, defendant could have sought a more definite statement); Moore v. Fidelity Fin. Servs., 869 F. Supp. 557, 559-60 (N.D. Ill. 1994); FDIC v. Wise, 758 F. Supp. 1414, 1418 (D. Colo. 1991).

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
American Nurses' Association v. State of Illinois
783 F.2d 716 (Seventh Circuit, 1986)
Airborne Beepers & Video, Inc. v. AT & T Mobility LLC
499 F.3d 663 (Seventh Circuit, 2007)
Moore v. Fidelity Financial Services, Inc.
869 F. Supp. 557 (N.D. Illinois, 1994)
Federal Deposit Ins. Corp. v. Wise
758 F. Supp. 1414 (D. Colorado, 1991)
Stepp v. Covance Cent. Lab. Servs., Inc.
931 F.3d 632 (Seventh Circuit, 2019)
Fadeel Shuhaiber v. Illinois Department of Correct
980 F.3d 1167 (Seventh Circuit, 2020)
Joanne Kaminski v. Elite Staffing, Inc.
23 F.4th 774 (Seventh Circuit, 2022)

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Cross v. St. Clair County Emergency Management Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cross-v-st-clair-county-emergency-management-administration-ilsd-2024.