In the case of Ji Guo Wu v. East Ocean Agriculture Corp., eight former employees of East Ocean Agriculture Corp (East Ocean) filed a lawsuit under the Fair Labor Standards Act (FLSA). The employees alleged various violations, which included failure to pay overtime wages, minimum wages, unpaid wages, and retaliation.
East Ocean operated a farm business in Delaware. Three of the eight employees worked as drivers who delivered vegetables from the farm to New York. The other five employees were farm workers who alleged unpaid wages. East Ocean sought dismissal based on jurisdictional and pleading requirements.
The court determined that the employer/employee relationship and individual/enterprise coverage were elements of an FLSA claim, not jurisdictional prerequisites. The complaint sufficiently alleged an employment relationship. Additionally, the employees engaged in interstate commerce or the production of goods for interstate commerce met the coverage requirement.
East Ocean also argued that the employees failed to state Delaware Minimum Wage Act (MWA) claims due to an agricultural exemption and Delaware Wage Payment and Collection Act (WPCA) claims based on the statute of limitations. The court agreed that all employees were employed in agriculture, exempting them from MWA minimum wage requirements. Claims under the WPCA were time-barred for some of the employees. The court granted partial dismissal but allowed an opportunity to amend certain claims.
Key lessons from this case:
- To state an overtime claim under the FLSA, employees must prove an employer/employee relationship, engagement in interstate commerce, or the production of goods for interstate commerce.
- Plaintiffs must provide specific periods during which they were not paid minimum wages, overtime wages, or any wages at all.
- The WPCA claims are subject to a one-year statute of limitations, and claims based on activity occurring before a specific date may be time-barred.
If you want to know more about overtime regulations, read our guide on Delaware Overtime Laws.
