Johnson v. Wave Comm GR LLC
Plaintiff Brett Johnson, on behalf of himself and other installers, sued Wave Comm GR LLC and its owners for alleged Fair Labor Standards Act (FLSA) and New York Labor Law (NYLL) violations concerning unpaid overtime. The defendants countered with an unjust enrichment claim. The court partially granted and partially denied both parties' summary judgment motions. It ruled that FLSA claims were subject to a statute of limitations, and Wave Comm could claim a retail or service establishment exemption for some periods under its Plan A compensation system, but not for periods where it failed to track hours. The court found Plan B's weighted halftime formula largely compliant but identified factual disputes regarding unreported work hours. Owners Robert Guillerault and Richard Ruzzo were deemed individually liable as FLSA employers, and the defendants' unjust enrichment counterclaim was dismissed.