What Happened in Felix vs. Weber Metals Reconsideration?
Plaintiff Elma Manliguez brought claims against Martin and Somanti Joseph, alleging involuntary servitude, Alien Tort Claims Act violation, intentional infliction of emotional distress, conversion, deprivation of overtime compensation, fraudulent inducement, and negligent misrepresentation. Defendants sought to dismiss all claims, arguing they were time-barred or lacked sufficient grounds. District Judge GARAUFIS denied the motion in its entirety, finding that a private civil cause of action exists for involuntary servitude under 18 U.S.C. § 1584, subject to New York's three-year personal injury statute of limitations. The court also determined that the ten-year statute of limitations from the Torture Victims Protection Act applied to the ATCA claim and that New York law allowed for overtime compensation for domestic employees. Furthermore, the court found the claims for fraudulent inducement and negligent misrepresentation were sufficiently pled under Rule 9(b).