SINGH v. BNO SERVICE STATION, LLC

CourtDistrict Court, D. New Jersey
DecidedJuly 10, 2025
Docket2:23-cv-04196
StatusUnknown

This text of SINGH v. BNO SERVICE STATION, LLC (SINGH v. BNO SERVICE STATION, LLC) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SINGH v. BNO SERVICE STATION, LLC, (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

HARJIT SINGH, on behalf of himself and all other persons No. 23-cv-04196 (MEF)(SDA) similarly situated,

OPINION and ORDER Plaintiff,

v. BNO SERVICE STATION, LLC, a/k/a EXXON et al.,

Defendants.

Table of Contents I. Background A. The Allegations B. The Lawsuit C. Procedural History D. The Court’s Approach II. Liability A. Jurisdiction 1. Subject-Matter Jurisdiction 2. Personal Jurisdiction B. Service C. The Plaintiff’s Claims 1. Overtime 2. Minimum Wage D. The Equities E. Conclusion III. Remedies IV. Conclusion * * * A gas station attendant sued his former employer, mainly for unpaid overtime. The Clerk of Court entered default, and the attendant has now moved for default judgment. The motion is granted in part and denied in part. * * * I. Background A. The Allegations The relevant allegations for now are as follows. A man worked as an attendant at a New Jersey gas station. See Amended Complaint (ECF 7) (“Complaint”) ¶¶ 6, 10-11. He “routinely worked approximately seventy . . . hours per workweek.” Id. ¶ 26. But rather than receiving an overtime rate for the hours he worked past the forty-hours-per-week mark, the attendant was paid a lower wage for those hours. See id. ¶¶ 27-28. Additionally, after the attendant was injured on the job, his employer directed him to rest up at home for a week. See id. ¶¶ 29-30. But when he tried to return to work, he learned he had been fired. See id. ¶¶ 31-33. B. The Lawsuit In light of the above, the gas station attendant,1 referred to from here as “the Plaintiff,” brought this lawsuit. He sued the company2 he used to work for, and two people said to be the company’s owners and/or managers.3 See id. ¶¶ 13-20. Collectively, they are called “the Defendants” from here.

1 Harjit Singh. 2 BNO Service Station, LLC, a/k/a Exxon. 3 Neslihan Kipge and Ugar Olgun. The Plaintiff pressed one federal claim, under the Fair Labor Standards Act (“FLSA”). See id. ¶¶ 37-41. And he brought four state claims. These are wage-underpayment claims under the New Jersey Wage and Hour Law (“NJWHL”), see id. ¶¶ 42-45, 50-55, and the New Jersey Wage Payment Law (“NJWPL”). See id. ¶¶ 46-49. And these are wrongful termination claims, under the New Jersey Workers’ Compensation Act, see id. ¶¶ 56-59, and under the common law, as interpreted by the New Jersey Supreme Court in Pierce v. Ortho Pharmaceutical Corp., 84 N.J. 58 (1980). See Complaint ¶¶ 60-64. C. Procedural History The Defendants have not appeared, and the Clerk of Court has filed an entry of default. See Clerk’s Entry of Default (March 26, 2024); see generally Fed. R. Civ. P. 55(a). The Plaintiff now moves for default judgment. D. The Court’s Approach The Court’s analysis is in two parts. First, the Court considers whether to grant the default judgment motion as to the Defendants’ liability on the FLSA and NJWHL claims.4 See Part II. And second, the Court determines whether to grant the default judgment motion as to the remedies the Plaintiff seeks. See Part III. II. Liability To assess a default judgment motion, four issues must be taken up: (1) jurisdiction; (2) service; (3) the merits of a plaintiff’s claim; and (4) the equities. See Baymont Franchise

4 Two things. First, there is no need to separately address the Plaintiff’s NJWPL claim. The default judgment motion would be resolved the same way regardless of whether it is or is not considered. Second, the Plaintiff’s wrongful termination claims, under the New Jersey Workers’ Compensation Act and state common law, are addressed in Part II.A.1. Sys., Inc. v. Narnarayandev, LLC, 348 F.R.D. 220, 227-31 (D.N.J. 2024). Move through these here. A. Jurisdiction 1. Subject-Matter Jurisdiction As to the FLSA claim, subject-matter jurisdiction is straightforward. It is supplied by the federal question statute, 28 U.S.C. § 1331. * * * As to the various New Jersey state law claims, see Part I.B., the Plaintiff invokes the supplemental jurisdiction statute, 28 U.S.C. § 1367. See Complaint ¶ 4.5 The supplemental jurisdiction statute supplies subject-matter jurisdiction over the Plaintiff’s NJWHL claims. See id. ¶¶ 42- 45, 50-55. The reason: those are based on the same allegations of underpaid wages as the Plaintiff’s federal FLSA claim. See 28 U.S.C. § 1367(a); Ajanel v. JC HVAC LLC, 2025 WL 1671318, at *1 (D.N.J. June 12, 2025). Does the Court have supplemental jurisdiction over the claims for wrongful termination under New Jersey common law and the New Jersey Workers’ Compensation Act? The relevant statute provides that the Court “shall have supplemental jurisdiction over all . . . claims that are so related to claims in the action within [its] original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution.” 28 U.S.C. § 1367(a). This generally means that supplemental jurisdiction can be exercised over state law claims if they share a “common nucleus of operative fact” with the federal claim that is on the table. 13D Charles A. Wright & Arthur R. Miller, Fed. Prac. & Proc. Juris. § 3567 (3d ed. 2025) (quoting United Mine Workers of Am.

5 The Plaintiff also cites the diversity statute. But that statute requires some of the parties be “citizens of different States.” 28 U.S.C. § 1332(a)(1). And all the parties here are said to be from New Jersey. See Complaint ¶¶ 9, 11, 13, 17. v. Gibbs, 383 U.S. 715, 725 (1966)); see also, e.g., De Asencio v. Tyson Foods, Inc., 342 F.3d 301, 307-08 (3d Cir. 2003). Do the Plaintiff’s state law wrongful termination claims share a “common nucleus of operative fact” with his federal FLSA claim? Not on the allegations here. The wrongful termination claims are about getting fired for seeking medical leave. The FLSA claim is about not getting paid overtime. These are different, one from the next. And while the claims grow out of the same workplace, and that makes for some overlap, “the fact that claims arise from . . . [the same] employment relationship will not necessarily mean that they are sufficiently related to support supplemental jurisdiction.” 13D Fed. Prac. & Proc. Juris. § 3567.1. To see the point, look to the Third Circuit’s decision in Lyon v. Whisman, 45 F.3d 758 (3d Cir. 1995). There, the plaintiff brought three claims: an unpaid overtime claim under the FLSA, and two Delaware state law claims based on her former employer’s refusal to pay certain bonuses. See id. at 758-59. The Third Circuit held that there was “an insufficient nexus between [the plaintiff’s] federal FLSA claim and her Delaware claims to justify supplemental jurisdiction over the latter.” Id. at 762. The only commonality, the Third Circuit said, was that all three claims were based on the employer-employee relationship between the parties.6 See id. But whereas the plaintiff’s “FLSA claim involved very narrow, well-defined factual issues about hours worked during particular weeks[,] [t]he facts relevant to her state law contract and tort claims . . . were quite distinct.” Id. at 763. So too here.

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SINGH v. BNO SERVICE STATION, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/singh-v-bno-service-station-llc-njd-2025.