Dennis Galik, Individually and on behalf of all Others similarly situated v. SBC Waste Solutions, Inc.

District Court, N.D. Illinois·Decided July 14, 2026·No. 1:25-cv-12915·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

DENNIS GALIK, Individually and on behalf of all ) Others similarly situated, ) ) Plaintiff, ) Case No. 25 C 12915 ) v. ) ) Judge Robert W. Gettleman SBC WASTE SOLUTIONS, INC., ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

Plaintiff Dennis Galik has sued defendant SBC Waste Solutions, Inc.—a provider of waste collection, recycling, and disposal services to commercial, industrial, and residential customers in Illinois—on behalf of himself and other similarly situated current and former employees of defendant. According plaintiff, he and the class members worked more than 40 hours per week for defendant, but were not paid “overtime of at least one and one-half their regular rates for all hours worked in excess” of 40 hours per week. He and the class members, he further alleges, also worked under 40 hours per week “on occasion,” but “were not fully compensated at their regular rate of pay for all hours worked.” He thus filed his complaint here—the operative complaint, titled “First Amended Collective/Class Action Complaint”— which alleges three claims: a claim for violations of the Fair Labor Standards Act of 1938 (“FLSA”), 29 U.S.C. §§ 201-19 (Count I); a claim for violations of the Illinois Minimum Wage Law (“IMWL”), 820 ILCS 105/1-105 (Count II); and a claim for violations of the Illinois Wage Payment and Collection Act (“IWPCA”), 820 ILCS 115/1-15 (Count III). Defendant has moved [21] to dismiss Count III under Fed. R. Civ. P. 12(b)(6), or alternatively, to require plaintiff to provide a more definite statement under Fed. R. Civ. P. 12(e). For the reasons below, the court denies without prejudice defendant’s motion. BACKGROUND

Plaintiff alleges the following facts in its complaint, which are taken as true in resolving defendant’s motion. Alam v. Miller Brewing Co., 709 F.3d 662, 665-66 (7th Cir. 2013). Defendant is a full-service solid waste company that is headquartered and licensed to do business in Illinois. Plaintiff and the putative class members worked for defendant in Illinois on an hourly basis, and “were responsible for maintaining and operating [defendant]’s vehicles, which were used to collect, transport, and dispose of [defendant]’s customers’ waste products.” During their employment, they typically worked 5 days a week and around 10 to 12 hours a day. Defendant has a policy under which it automatically deducted 30 minutes for a meal period from their daily time. But plaintiff and the class worked “through their meal periods without pay.” So based on the meal-break policy, plaintiff and the class ended up “working

straight time hours and overtime hours for which they were . . . not compensated” at required rates. In Count I, plaintiff alleges that defendant violated §§ 207 and 215(a)(2) of the FLSA by employing individuals for workweeks longer than 40 hours without compensating them “at rates at least one and one-half times the regular rates for which they were employed.” Plaintiff therefore seeks “wages for all hours worked in excess of [40] hours per workweek . . . in an amount equal to one-and-a-half times their regular rate of pay, plus liquidated damages, attorneys’ fees and costs.”

2 In Count II, plaintiff alleges that defendant violated the IMWL by failing to pay plaintiff and the “IMWL Class Members overtime wages at rates not less than 1.5 times their regular rates for all hours worked after [40] in a workweek, including off-the-clock hours worked . . . during their unpaid meal breaks.” Plaintiff alleges that they “are entitled damages, including treble

damages, monthly statutory damages, and reasonable attorneys’ fees” under 820 ILCS 105/12(A). In Count III, plaintiff alleges that defendant violated the IWPCA. According to plaintiff, “[a]s part of the agreement for employment and in addition to the Collective Bargaining Agreement [‘CBA’] between the Parties, [defendant] agreed to pay” plaintiff and the “IWPCA Class Member[s] an hourly rate for all non-overtime hours they worked in a workweek, an[d] another set hourly rate for all overtime hours worked in a workweek.” In particular, defendant “agreed that in exchange for his labor,” plaintiff “would be paid approximately $32.00 per hour worked up to [40] hours and approximately $48.00 per hour for each hour worked in excess of [40] hours per workweek.” Plaintiff and the IWPCA Class Members “accepted [defendant]’s

offer.” “This agreement included all time” that plaintiff and the IWPCA Class Members worked on defendant’s behalf, “including time worked during their unpaid meal-breaks.” (Emphasis in complaint). But defendant “unilaterally broke the agreement by not compensating” them “for all hours worked at the [agreed] rates.” As a result, plaintiff alleges, he and the class are “entitled damages, monthly statutory damages, and reasonable attorneys’ fees” under 820 ILCS 115/14(A).

3 DISCUSSION The court begins (and ends) with defendant’s motion for a more definite statement under Rule 12(e). Under Rule 12(e), “[a] party may move for a more definite statement of a pleading” when the pleading “is so vague or ambiguous that the party cannot reasonably prepare a

response.” Fed. R. Civ. P. 12(e). “A motion for a more definite statement under Rule 12(e) is intended only to clear up confusion and not to replace traditional discovery.” Direct Commc’ns, Inc. v. Horizon Retail Const., Inc., 387 F. Supp. 2d 828, 831 (N.D. Ill. 2005). Defendant contends that a more definite statement is needed here to clear up confusion about the “agreement” alleged in Count III. According defendant, the complaint “makes clear that there are two agreements at issue: the CBA and another unknown agreement.” Indeed, defendant point outs, the complaint states: “As part of the agreement for employment and in addition to the [CBA] . . . .” (Emphasis by defendant). But, defendant argues, plaintiff gives insufficient details about this unspecified non-CBA agreement: “Plaintiff gives no indication whether the ‘agreement’ . . . is written or oral”; “[w]hile rates of pay are alleged . . ., [plaintiff]

recites no other terms or identifying information”; and “without specifying which one (the CBA or the unknown agreement), [plaintiff] alleges that [defendant] ‘unilaterally broke the agreement.” (Emphasis by defendant). In response, plaintiff argues that it “clearly plead[ed] a cause of action under the IWPCA against” defendant. He contends that “[i]t is through the discovery process—not the pleading process—that [defendant] will obtain all of the requisite details surrounding the agreement between [p]laintiff, the IWPCA Class Members, and [defendant].” Yet, plaintiff hedges, if the

4 court finds that the complaint’s allegations are lacking, the court should grant leave to amend the complaint to cure any deficiencies. The court finds that a more definite statement is needed here. To survive a Rule 12(e) motion on a claim involving an agreement, “the plaintiff must recite the relevant agreement, the

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Dennis Galik, Individually and on behalf of all Others similarly situated v. SBC Waste Solutions, Inc., (N.D. Ill. 2026).

Dennis Galik, Individually and on behalf of all Others similarly situated v. SBC Waste Solutions, Inc. (Dennis Galik, Individually and on behalf of all Others similarly situated v. SBC Waste Solutions, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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