Curtin-Wilding v. Trustees of Boston University

CourtDistrict Court, D. Massachusetts
DecidedAugust 27, 2025
Docket1:25-cv-10432
StatusUnknown

This text of Curtin-Wilding v. Trustees of Boston University (Curtin-Wilding v. Trustees of Boston University) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Curtin-Wilding v. Trustees of Boston University, (D. Mass. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

CIVIL ACTION NO. 25-10432-RGS

LYDIA CURTIN-WILDING, individually and on behalf of all others similarly situated

v.

TRUSTEES OF BOSTON UNIVERSITY

MEMORANDUM AND ORDER ON MOTION FOR JUDGMENT ON THE PLEADINGS, MOTION TO AMEND THE COMPLAINT, AND MOTION TO CERTIFY QUESTIONS OF LAW

August 27, 2025 STEARNS, D.J. Before the court is defendant Trustees of Boston University’s (BU) motion for judgment on the pleadings, Fed. R. Civ. P. 12(c), as well as plaintiff Lydia Curtin-Wilding’s motions to amend the Complaint, Fed. R. Civ. P. 15(a)(2), and to certify certain questions of law to the Massachusetts Supreme Judicial Court (SJC), Mass. S.J.C. Rule 1:03. For the following reasons, the motion for judgment on the pleadings is allowed. The motions to amend the Complaint and certify questions of law to the SJC are denied. BACKGROUND The court assumes familiarity with the facts of the case. Since August of 2015, BU, a private, nonprofit research institution of higher education with campuses in Boston, employed Curtin-Wilding as a salaried Lecturer. Compl. (Dkt. # 1) ¶ 13. BU paid Curtin-Wilding on a monthly basis on or

about the last business day of each month. Id. ¶¶ 15, 18. She claims that BU’s policy resulted in the wages that she and the putative class members earned in the first half of the month from February 18, 2022, until August 1, 2023, being paid approximately nine days late, in violation of the Massachusetts

Wage Act, Mass. Gen. Laws ch. 149, § 148 (Wage Act). Id. ¶¶ 18, 23. Curtin- Wilding filed this putative class action on February 21, 2025. See Dkt. # 1. On May 23, 2025, this court denied BU’s motion to dismiss the Complaint.

See Dkt. # 34. On June 6, 2025, BU filed its Answer. See Dkt. # 38. On July 4, 2025, Massachusetts Governor Maura Healey signed a budget bill into law, which included Section 113 of Chapter 9 of the Acts and Resolves of 2025 (Section 113). Section 113 provides immunity to nonprofit

institutions of higher education and nonprofit organizations that comprise a health care delivery system from Wage Act lawsuits targeting the employers’ monthly payment of wages to employees. See 2025 Mass. Acts. ch. 9, § 113.1

1 On April 16, 2025, the Joint Committee on Labor and Workforce Development held a hearing on two bills, Bill S.1369 and Bill H.2164, which were the precursors of Section 113. See Daggett v. Comm’n on Gov’t Ethics & Election Pracs., 205 F.3d 445, 456 n.9 (1st Cir. 2000) (holding that the court may take judicial notice of legislative facts). At the hearing, Rob McCarron, the President of the Association of Independent Colleges and Universities in Massachusetts, testified that the proposed legislation would Following the passage of Section 113, on July 25, 2025, BU filed a motion for judgment on the pleadings. See Dkt. # 39. Three days later, on

July 28, 2025, Curtin-Wilding filed a motion to amend the Complaint. See Dkt. # 41. On August 1, 2025, she filed a motion to certify a question of law to the SJC. See Dkt. # 48. On August 19, 2025, Curtin-Wilding filed another motion to certify additional questions of law to the SJC. See Dkt. # 56.

Before the court are the pertinent motions, which the court will discuss in turn. DISCUSSION

1. Motion for Judgment on the Pleadings Rule 12(c) permits a party to move for judgment on the pleadings at any time “[a]fter the pleadings are closed,” as long as the motion does not delay the trial. Fed. R. Civ. P. 12(c). A Rule 12(c) motion differs from a Rule

12(b)(6) motion in that it implicates the pleadings as a whole. “In the

correct “unintended consequences” of the Wage Act, manifesting in the filing of multiple class action lawsuits against universities in Massachusetts. See Higher Educ. Hearing (Constitutional Amendment/Higher Education: Hearing on S.1369, H.2164 Before the Joint Comm. on Lab. & Workforce Dev., 194th Gen. Ct. (Mass. 2025) (statement of Rob McCarron) (Dkt. # 50- 2)) at 2:23. On May 29, 2025, the bills were also discussed at a supplemental budget hearing. The Senate proposed amendments to the legislation and appointed a joint conference committee to reconcile the differences. On June 30, 2025, the House and Senate accepted the conference committee reports and enacted the budget legislation. archetypical case, the fate of such a motion will depend upon whether the pleadings, taken as a whole, reveal any potential dispute about one or more

of the material facts.” Gulf Coast Bank & Trust Co. v. Reder, 355 F.3d 35, 38 (1st Cir. 2004). “Because [a Rule 12(c)] motion calls for an assessment of the merits of the case at an embryonic stage, the court must view the facts contained in the pleadings in the light most favorable to the nonmovant and

draw all reasonable inferences therefrom. . . .” Perez-Acevedo v. Rivero- Cubano, 520 F.3d 26, 29 (1st Cir. 2008), quoting R.G. Fin. Corp. v. Vergara- Nunez, 446 F.3d 178, 182 (1st Cir. 2006).

BU argues that judgment on the pleadings is appropriate because Section 113 provides statutory immunity to BU based on a plain reading of the legislation. See Dkt. # 40 at 6. Curtin-Wilding concedes that Section 113 “grants immunity only to ‘nonprofit institutions,’” see Dkt. # 42-1 at 2, but

challenges the constitutionality of Section 113, claiming that it: (a) is an unreasonable and inequitable retroactive statute under the United States and Massachusetts Constitutions, see Dkt. # 50 at 9; (b) is an impermissible selective exemption to standing laws in violation of Article X of the

Massachusetts Declaration of Rights, see Dkt. # 50 at 6; and (c) violates the remedies clause of Article XI of the Massachusetts Declaration of Rights, see Dkt. # 50 at 20. The Wage Act requires that: Every person having employees in his service shall pay weekly or bi-weekly each such employee the wages earned by him to within six days of the termination of the pay period during which the wages were earned if employed for five or six days in a calendar week, or to within seven days of the termination of the pay period during which the wages were earned if such employee is employed seven days in a calendar week.

Mass. Gen. Laws ch. 149, § 148.

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