Molina-Aranda v. Black Magic Enterprises, LLC, No. 19-50638 (5th Cir. 2020)
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Plaintiff filed suit against Carmen and Jessie Ramirez and their company, Black Magic, alleging that the Ramirezes violated the Racketeer Influenced and Corrupt Organizations Act (RICO) and the Fair Labor Standards Act (FLSA). Plaintiffs claimed that the Ramirezes brought them to the United States under the H-2B visa program to work as construction workers, but once plaintiffs arrived in the country, they were made to work as truck drivers. Plaintiffs also claimed that the Ramirezes unlawfully deducted from their paychecks, denied them overtime pay, and sometimes failed to pay them entirely. The district court dismissed the claims for failure to state a claim, declined to exercise supplemental jurisdiction over plaintiffs' related state law claims, and denied plaintiffs' later-filed motion for leave to amend the complaint.
The Fifth Circuit affirmed the district court's dismissal of plaintiffs' RICO claims where plaintiffs failed to adequately plead proximate causation; affirmed the district court's denial of plaintiffs' motion for leave to amend; reversed the dismissal of plaintiffs' FLSA claims where plaintiffs have adequately alleged that they handled goods or materials that had at some point travelled interstate, and that they lost wages as a result of the alleged FLSA violations; vacated the dismissal of the state law claims for new consideration of supplemental jurisdiction; and remanded for further proceedings.
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