Floyd v. DoorDash Inc

CourtDistrict Court, W.D. Washington
DecidedMay 22, 2024
Docket2:23-cv-01740
StatusUnknown

This text of Floyd v. DoorDash Inc (Floyd v. DoorDash Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Floyd v. DoorDash Inc, (W.D. Wash. 2024).

Opinion

1 The Honorable Barbara J. Rothstein

5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE

7 NO. 23-cv-1740-BJR ALEXANDER FLOYD, 8 ORDER DENYING AS MOOT Plaintiff, MOTION TO DISMISS AND 9 REMANDING CASE v. 10 DOORDASH, INC., et al., 11 Defendants. 12

13 I. INTRODUCTION 14 The Equal Pay and Opportunities Act (“EPOA”), RCW 49.58, promotes pay equity in 15 Washington State by addressing business practices that contribute to income disparities. On January 16 1, 2023, a revised provision took effect, which requires certain employers to disclose the wage scale 17 or salary range, and a general description of other compensation and benefits, in each posting for 18 an available position. RCW 49.58.110.1 Employees and job applicants are entitled to remedies for 19 violations of this provision, which may include statutory damages. Id. Within a few months, a few 20 plaintiffs, represented by Emery Reddy, PLLC, filed multiple putative class-action lawsuits against 21

22 1 A detailed statutory background may be found in this Court’s decisions in related cases. See, e.g., Floyd v. Insight Global LLC, et al., 23-CV-1680-BJR, 2024 WL 2133370, at *1-2 (W.D. Wash. May 10, 2024); Atkinson v. Aaron’s 23 LLC, et al., 23-CV-1742-BJR, 2024 WL 2133358, at *1-2 (W.D. Wash. May 10, 2024).

24 ORDER DENYING AS MOOT MOTION TO DISMISS AND REMANDING CASE 1 various companies who had job postings that are alleged to be non-compliant with the EPOA job- 2 posting provision. This case is one of 27 lawsuits with virtually identical complaints filed in King 3 County Superior Court and subsequently removed to this Court by the defendants. This case was 4 removed to this Court on November 13, 2023, and Defendant, DoorDash, Inc. (“DoorDash”), filed 5 a motion to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(6) and 12(f). Mot., ECF No. 6 9. Having reviewed the materials2 and the relevant legal authorities, the Court will remand this case 7 to King County Superior Court pursuant to 28 U.S.C. § 1447(c) and deny the motion to dismiss as 8 moot. The reasoning for the Court’s decision follows. 9 II. BACKGROUND 10 On August 7, 2023, Alexander Floyd applied through LinkedIn for a job opening with 11 DoorDash. Compl. ¶¶ 8, 18; Ex. 1, ECF No. 1-1. He alleges that the job posting did not disclose

12 the wage scale or salary range. Id. ¶¶ 17-18, 31. Mr. Floyd filed suit against DoorDash in the King 13 County Superior Court on October 10, 2023. Id. at 9. He claims to represent more than 40 potential 14 class members who also applied for jobs with DoorDash for positions that did not disclose the wage 15 scale or salary range. Id. ¶ 17. Mr. Floyd asserts three causes of action: (1) Violation of RCW 16 49.58.110; (2) Injunctive Relief; and (3) Declaratory Relief.” Compl. ¶¶ 30-39. He seeks statutory 17 damages, costs, and reasonable attorneys’ fees pursuant to RCW 49.58.070(1). Id. at 8. 18 DoorDash removed the case to this Court on November 13, 2023, on the basis of diversity 19 jurisdiction, 28 U.S.C. § 1332(a). Notice of Removal, ECF No. 1. DoorDash filed a motion to 20 dismiss pursuant to Federal Rules of Civil Procedure 12(b)(6) and motion to strike pursuant to Rule 21 12(f), arguing that Mr. Floyd fails to plead a plausible claim primarily because he does not allege

22 2 Including the motion, ECF No. 9; response in opposition, ECF No. 20; and reply, ECF No. 22; together with multiple 23 exhibits as well as related motions and responses.

24 ORDER DENYING AS MOOT MOTION TO DISMISS AND REMANDING CASE 1 that he applied for the posted position in good faith with the intent to gain employment. Mot. 2, 2 ECF No. 9. DoorDash also asserts that the job Mr. Floyd applied for had the requisite compensation 3 information in its posting and argues that Mr. Floyd’s class action allegations should be stricken as 4 too broad. Id. at 2-3. Although only raised in its reply brief, DoorDash contends that Mr. Floyd 5 lacks standing and has no statutory right to bring a civil action. Reply 7.3 6 III. DISCUSSION 7 In his response to DoorDash’s motion, Mr. Floyd noted that “standing was conferred the 8 moment Defendant violated Mr. Floyd’s right to receive statutorily required information.” Opp’n 6 9 n.3 (citing cases). DoorDash then argued that Mr. Floyd failed to allege an injury in fact because 10 he merely submitted an application, was not interviewed or offered a job, and as such, the alleged 11 harm is merely speculative. Reply 7. The parties raise the issue of standing in passing, and neither

12 party’s argument is developed further. However, whether Plaintiffs have Article III standing to 13 proceed with this lawsuit implicates the Court’s subject matter jurisdiction. See Warth v. Seldin, 14 422 U.S. 490, 498 (1975) (stating that standing is jurisdictional). Even in a class action, “standing 15 is the threshold issue . . . . If the individual plaintiff lacks standing, the court need never reach the 16 class action issue.” Lierboe v. State Farm Mut. Auto. Ins. Co., 350 F.3d 1018, 1022 (9th Cir. 2003). 17 “[T]o establish standing, a plaintiff must show (i) that he suffered an injury in fact that is 18 concrete, particularized, and actual or imminent; (ii) that the injury was likely caused by the 19

20 3 The Court notes that while it need not consider arguments first raised in a reply brief, there are exceptions to this rule. See Kroeber v. GEICO Ins. Co., C14-726RSL, 2015 WL 11669649, at *2 (W.D. Wash. Mar. 31, 2015). One 21 such exception is when new arguments are raised by the opposing party’s response memoranda. Id. (citing Rockwell v. Chase Bank USA, N.A., 2012 WL 4846177, at *1 n. 2 (W.D. Wash. Oct. 11, 2012)). Here, Mr. Floyd’s response 22 raised the issue of standing. Opp’n 6 n.3. Regardless, “[f]ederal courts are required sua sponte to examine jurisdictional issues such as standing.” Chapman v. Pier 1 Imports (U.S.) Inc., 631 F.3d 939, 954 (9th Cir. 2011). Although Mr. Floyd has not moved to remand this case, “[i]f at any time before final judgment it appears that the district court lacks 23 subject matter jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c).

24 ORDER DENYING AS MOOT MOTION TO DISMISS AND REMANDING CASE 1 defendant; and (iii) that the injury would likely be redressed by judicial relief.” TransUnion LLC v. 2 Ramirez, 594 U.S. 413, 423 (2021) ((citing Lujan v. Defenders of Wildlife, 504 U.S. 555, 560–61 3 (1992)). “The party invoking federal jurisdiction bears the burden of establishing these elements.” 4 Lujan, 504 U.S. at 561.

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Floyd v. DoorDash Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/floyd-v-doordash-inc-wawd-2024.