Maldonado v. BTB Events & Celebrations, Inc.
This case involves claims by food-delivery workers against catering companies (Between the Bread) for underpayment under federal (FLSA) and state (NYLL) law, centering on an 11% mandatory delivery surcharge. Plaintiffs argued this surcharge was a tip or gratuity that they were entitled to, while defendants maintained it was an administrative charge. The court analyzed whether the 11% surcharge constituted a gratuity under both FLSA and NYLL, applying different legal standards. For FLSA claims and NYLL claims prior to January 1, 2011, the court found in favor of the defendants, ruling the surcharge was not a gratuity. However, for NYLL claims from January 1, 2011, onwards, the court found in favor of the plaintiffs, concluding the surcharge was a purported gratuity due to stricter NYSDOL regulations and the employer's insufficient notification.