Zatorski v. Island Transp. Corp.

2024 NY Slip Op 34234(U)
CourtNew York Supreme Court, New York County
DecidedDecember 2, 2024
DocketIndex No. 153771/2023
StatusUnpublished

This text of 2024 NY Slip Op 34234(U) (Zatorski v. Island Transp. Corp.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zatorski v. Island Transp. Corp., 2024 NY Slip Op 34234(U) (N.Y. Super. Ct. 2024).

Opinion

Zatorski v Island Transp. Corp. 2024 NY Slip Op 34234(U) December 2, 2024 Supreme Court, New York County Docket Number: Index No. 153771/2023 Judge: Louis L. Nock Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 153771/2023 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 12/02/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. LOUIS L. NOCK PART 38M Justice ---------------------------------------------------------------------------------X INDEX NO. 153771/2023 JACEK ZATORSKI, individually and on behalf of all other persons similarly situated, MOTION DATE 07/14/2023

Plaintiff, MOTION SEQ. NO. 001

-v- DECISION + ORDER ON ISLAND TRANSPORTATION CORPORATION, MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document numbers (Motion 001) 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, and 44 were read on this motion to DISMISS .

LOUIS L. NOCK, J.S.C.

Upon the foregoing documents, defendant’s motion to dismiss the complaint based on

documentary evidence (CPRL 3211 [a] [1]) is denied, for the reasons set forth in the opposition

memorandum of law (NYSCEF Doc. No. 38), in which the court concurs, as summarized herein.

This is a putative class action complaint in which plaintiff alleges that he and his

coworkers were regularly underpaid. Specifically, plaintiff alleges that defendant, a petroleum

products carrier, regularly failed to pay overtime for hours worked in excess of 40 hours per

week. Defendant argues that it is exempt from any overtime requirements for plaintiff and the

putative class because they are subject to the jurisdiction of the Federal Department of

Transportation (“DOT”), and the overtime standards of the Federal Department of Labor

(“DOL”) as provided by the Fair Labor Standards Act (“FLSA”) (29 USC §§ 201, et seq.) do not

153771/2023 ZATORSKI, JACEK ET AL vs. ISLAND TRANSPORTATION CORPORATION Page 1 of 5 Motion No. 001

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apply.1 Both sides agree that whether the Motor Carrier Act exemption (the “MCA exemption”)

from overtime applies is dispositive of this case, with plaintiff arguing that defendant has not

submitted sufficient documentary evidence to warrant dismissal at this early stage.

“On a motion to dismiss pursuant to CPLR 3211, the pleading is to be afforded a liberal

construction” (Leon v Martinez, 84 NY2d 83, 87 [1994]). “[The court] accept[s] the facts as

alleged in the complaint as true, accord[ing] plaintiff the benefit of every possible favorable

inference, and determin[ing] only whether the facts as alleged fit within any cognizable legal

theory” (id. at 87-88). Ambiguous allegations must be resolved in plaintiff’s favor (JF Capital

Advisors, LLC v Lightstone Group, LLC, 25 NY3d 759, 764 [2015]). “The motion must be

denied if from the pleadings' four corners factual allegations are discerned which taken together

manifest any cause of action cognizable at law” (511 West 232nd Owners Corp. v Jennifer

Realty Co., 98 NY2d 144, 152 [2002] [internal citations omitted]). “[W]here ... the allegations

consist of bare legal conclusions, as well as factual claims either inherently incredible or flatly

contradicted by documentary evidence, they are not entitled to such consideration” (Ullmann v

Norma Kamali, Inc., 207 AD2d 691, 692 [1st Dept 1994]).

“When, as here, a defendant moves for dismissal of a cause of action under CPLR

3211(a)(1), their documentary evidence must utterly refute the plaintiff's factual allegations,

conclusively establishing a defense as a matter of law” (Himmelstein, McConnell, Gribben,

Donoghue & Joseph, LLP v Matthew Bender & Co., Inc., 37 NY3d 169, 175 [2021] [internal

quotation marks and citation omitted]). “To be considered documentary, evidence must be

unambiguous and of undisputed authenticity, that is, it must be essentially unassailable” (Bath &

Twenty, LLC v Federal Sav. Bank, 198 AD3d 855 [2d Dept 2021]).

1 The New York Labor Law and relevant implementing regulations track the provisions of the FLSA for purposes of overtime calculations (12 NYCRR 142-2.2; e.g. Anderson v Ikon Off. Sols., Inc., 38 AD3d 317 [1st Dept 2007]). 153771/2023 ZATORSKI, JACEK ET AL vs. ISLAND TRANSPORTATION CORPORATION Page 2 of 5 Motion No. 001

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The FLSA provides, generally, for one and one-half times the rate of pay for any hours

over 40 per week worked by an employee, subject to a number of exemptions (29 USC § 207).

One of the listed exemptions is “any employee with respect to whom the Secretary of

Transportation has power to establish qualification and maximum hours of service pursuant to

the provisions of section 31502 of Title 49,” a provision of the Motor Carrier Act of 1935

(“MCA”) (29 USC § 213 [b] [1]). In order to avoid subjecting employers to overlapping

regulations, if the DOT is authorized to set hours for an employee, then the FSLA’s overtime

provisions do not apply (Fox v Commonwealth Worldwide Chauffeured Transp. of NY, LLC, 865

F Supp 2d 257, 264 [EDNY 2012], citing Levinson v. Spector Motor Serv., 330 US 649, 661

[1947]).

In order for the MCA exemption to apply, the employer must operate as a “motor carrier”

or “motor private carrier” (Dauphin v Chestnut Ridge Transp., Inc., 544 F Supp 2d 266, 273

[SDNY 2008], citing Boutell v Walling, 327 US 463, 467 [1946]), and the employee’s activities

“must affect[sic] vehicular ‘safety of operations in interstate or foreign commerce’” (id., quoting

Pyramid Motor Freight Corp. v. Ispass, 330 US 695, 698 [1947]). Drivers such as the putative

class members are within the class of those whose work effects “vehicular safety of operations”

(Morris v McComb, 332 US 422, 430 [1947] [“The drivers are full-time drivers of motor

vehicles well within the definition of that class of work by the Commission if the work is done in

interstate commerce”]). The interstate commerce prong may be satisfied where interstate travel

is “a natural, integral and apparently inseparable part” of plaintiff’s duties (id. at 433).

Determination of whether an employee’s work qualifies is a fact intensive analysis, and a court

may consider “the method by which the employer assigns the interstate activity to the pertinent

class of employees, the nature of the employer's business, and perhaps to a lesser degree, the

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proportion of interstate-to-intrastate employee activity” (Quartararo v J. Kings Food Serv.

Professionals, Inc., 17-CV-7390 (RRM), 2021 WL 1209716, at *9 [EDNY Mar. 31, 2021]

[internal quotation marks and citation omitted]), as well as whether “interstate commerce trips

were distributed generally throughout the year and their performance was shared

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Related

Boutell v. Walling
327 U.S. 463 (Supreme Court, 1946)
Levinson v. Spector Motor Service
330 U.S. 649 (Supreme Court, 1947)
Pyramid Motor Freight Corp. v. Ispass
330 U.S. 695 (Supreme Court, 1947)
Morris v. McComb
332 U.S. 422 (Supreme Court, 1948)
Leon v. Martinez
638 N.E.2d 511 (New York Court of Appeals, 1994)
511 West 232nd Owners Corp. v. Jennifer Realty Co.
773 N.E.2d 496 (New York Court of Appeals, 2002)
Dauphin v. Chestnut Ridge Transportation, Inc.
544 F. Supp. 2d 266 (S.D. New York, 2008)
JF Capital Advisors, LLC v. The Lightstone Group, LLC
37 N.E.3d 725 (New York Court of Appeals, 2015)
Bath & Twenty, LLC v. Federal Sav. Bank
2021 NY Slip Op 05685 (Appellate Division of the Supreme Court of New York, 2021)
Anderson v. Ikon Office Solutions, Inc.
38 A.D.3d 317 (Appellate Division of the Supreme Court of New York, 2007)
Tsimerman v. Janoff
40 A.D.3d 242 (Appellate Division of the Supreme Court of New York, 2007)
Ullmann v. Norma Kamali, Inc.
207 A.D.2d 691 (Appellate Division of the Supreme Court of New York, 1994)

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2024 NY Slip Op 34234(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/zatorski-v-island-transp-corp-nysupctnewyork-2024.