Acton v. Powerline Cycles Inc.

DECISION AND ORDER Following the conclusion of the trial in this case, the Court ordered the parties to brief the issue of Plaintiff’s standing to bring his claims for violations of Sections 195(1) and 195(3) of the New York Labor Law (“NYLL”). See ECF No. 80 (“July 2 Order”). In accordance with the Court’s order, Plaintiff filed his submission on July 29, 2024, ECF No. 83 (“Pl.’s Post-trial Mem.”), and Defendants filed their responsive submission on August 26, 2024, ECF No. 84 (“Defs.’ Post-trial Mem.”). Plaintiff did not file any papers in reply. For the reasons that follow, the Court finds that Plaintiff lacked standing to bring these claims in federal court, and the claims are hereby DISMISSED WITHOUT PREJUDICE. BACKGROUND Among the claims asserted by Plaintiff in this action were claims for violations of the NYLL based on Defendants’ alleged failure to provide Plaintiff with the requisite wage notice at the time of hiring and wage statements at the time of each payment of wages. See NYLL §§195(1), 195(3). While Plaintiff alleged in the Complaint that Defendants failed to comply with the statutory wage notice and wage statement requirements and cited the relevant statutory provisions, Plaintiff did not specify in the Complaint any concrete injury he suffered as a result of the alleged wage notice and wage statement violations. See ECF No. 1 (Complaint)