Xue Ming Wang v. Abumi Sushi Inc.
Plaintiff Xue Ming Wang sued Abumi Sushi Inc. and Qing Zhong Li for Fair Labor Standards Act (FLSA), New York Labor Law (NYLL), and New York General Business Law § 349 violations, stemming from his employment as a delivery worker. The core legal dispute centered on whether the defendants, who acquired the restaurant's assets in June 2015, were liable for violations predating the sale under successor liability doctrines. The Court considered both traditional common-law and federal common-law 'substantial continuity' tests. It concluded that the traditional test did not apply due to lack of ownership continuity, and under the 'substantial continuity' test, the plaintiff failed to prove the defendants had notice of the alleged pre-sale violations. Consequently, the Court granted the defendants' motion for partial summary judgment, denied the plaintiff's motion, and dismissed claims related to pre-June 2, 2015 conduct against the appearing defendants.