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New York Court Discusses Jurisdiction Over State and Federal Employment Claims

December 17, 2020

There are numerous statutes that protect New York employees from being treated unfairly at work, including wage and hour laws. Thus, employers that fail to pay employees fair wages or provide workers with wage notices may be held accountable for civil damages. Frequently, employers who violate wage laws will fail to comply with other statutes designed to protect workers as well, which is also actionable. In a recent ruling, a district court sitting in New York discussed whether it could exercise jurisdiction over state law claims brought in the same matter as wage claims. If you believe your employer violated your wage rights, you should speak to a skilled New York wage and hour claim attorney to discuss your options.

The Plaintiff’s Claims

Reportedly, the plaintiff worked as a waitress for the defendant restaurant. Throughout her employment, she was paid per shift. The defendant never provided her with wage statements or wage notices. The defendant also did not pay her spread of hours pay, as required by New York’s labor laws. She worked for the defendant for approximately three years before she informed her manager that she was pregnant.

It is alleged that the plaintiff did not request any accommodations for her pregnancy but was ultimately terminated regardless. She filed a federal lawsuit against the defendant, alleging violations of the Fair Labor Standards Act and New York State wage and labor laws, as well as claims of unlawful discharge in violation of New York State and City human rights laws. The parties filed cross-motions for summary judgment. In reviewing the motions, the court addressed, in part, whether it could exercise jurisdiction over the plaintiff’s state law claims.

Federal Courts’ Jurisdiction in Employment Cases

The court explained the circumstances under which a district court hearing Fair Labor Standards Act and New York Labor Law claims can exercise supplemental jurisdiction over other state law claims. Generally, if the only possible common nucleus of operative fact between the claims is the existence of a common employment relationship, the court has no supplemental jurisdiction. In other words, without some evidence of a factual connection between claims, the mere existence of an employment relationship is insufficient to establish jurisdiction.

Conversely, the court noted that there will be supplemental jurisdiction over state law claims if they are in some way related to the events or facts that gave rise to the Fair Labor Standards Act claims. In the subject case, the court found that the factual allegations in support of the plaintiff’s pregnancy discrimination claims did not significantly overlap with her wage and hour claims, such that they provided grounds for the court to exercise supplemental jurisdiction. As such, the court granted the defendant’s motion for summary judgment as to these claims due to lack of jurisdiction.

Speak to a Trusted Employment Attorney in New York

Employees aggrieved by unlawful practices in the workplace often have numerous avenues to pursue their claims and should seek legal counsel regarding their rights. If you were denied appropriate pay, you might be able to file a wage and hour claim against your employer, and it is prudent to consult a lawyer. The trusted New York employment attorneys of Gerstman Schwartz LLP can advise you of your rights and help you to seek any damages you may be owed. You can reach us via our form online or by calling us at (212) 227-7070 for our Manhattan office or at (516) 880-8170 for our Garden City office to set up a meeting.

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