A recent decision from the U.S. District Court for the District of Massachusetts provides an interesting analysis of the relationship between federal labor law and wage claims asserted by unionized employees. In Hayes v. Aramark Sports, LLC, two plaintiffs sued Aramark Sports, the concessionaire who provides food and beverage service at Fenway Park, for allegedly retaining service charges that should have been turned over to the servers under Massachusetts General Laws ch. 149, § 152A (the Tip Statute). The plaintiffs also claimed that Aramark failed to properly compute overtime payments and violated the state statute requiring prompt payment of wages due. In addition, the plaintiffs claimed Aramark’s failure to comply with these statutes gave rise to claims for unjust enrichment, breach of contract, and interference with advantageous relations.
Aramark argued that some of the plaintiffs’ claims were preempted by federal law because they implicated the terms of its collective bargaining agreement (CBA) with its unionized employees. The federal Labor-Management Relations Act allows parties to a CBA to sue for a breach of the agreement, and preempts other legal claims that would require a court to interpret the terms of the CBA. The Court found that the CBA contained detailed provisions setting rates of pay that employees were to receive in a variety of circumstances. Because the plaintiffs’ breach of implied contract claim, unjust enrichment claim, and overtime claim each would require an interpretation of the CBA’s pay provisions, the Court found that they were preempted. Similarly, the Court held that the plaintiffs’ claims under the prompt payment of wages statute were preempted to the extent that those claims were based on an underlying allegation that Aramark had not paid them all sums they were due because the amount they were owed was dictated by the CBA.
The Court also dismissed the plaintiffs’ interference with advantageous relations claim, which asserted that Aramark had interfered with the relationship between the servers at Fenway Park and the stadium’s patrons by failing to give the servers all service fees and gratuities collected from the patrons. The Court reasoned that there was no direct business relationship between the patrons and the servers because the service fees at issue were automatically added to the patrons’ bills and were “not a discretionary payment based on [their] perception of the quality of the service.”
The District Court’s rejection of the plaintiffs’ efforts to expand their claims is a positive sign for employers. The conglomeration of multiple claims in wage cases is an increasingly common tactic that plaintiffs’ lawyers use to increase the burden of litigation on employers and increase the value of claims. The ability to dispose of extraneous claims in such cases at an early stage, particularly those that expand employers’ exposure, is vital to employers’ effective defense in these onerous wage and hour class action lawsuits.