Guthrie v. Rainbow Fencing Inc.
113 F.4th 300 (2d Cir. 2024)
U.S. Court of Appeals for the Second Circuit · August 30, 2024
What the court decided
To sue in federal court over missing or inaccurate wage notices and pay statements, an employee must show a connection between the paperwork violation and a real-world harm, such as being kept from noticing an underpayment. A technical violation alone is not enough for federal standing, and the harm need not exceed the underlying wage violation.
Who won
Affirmed. The employee kept his default judgment for unpaid wages but lost the notice claims.
Why it matters for salespeople
State courts do not apply this federal requirement, so where a case is filed can decide whether these claims survive.
Key passage: 113 F.4th 300 (2d Cir. 2024) at 304-310.
Read the decision (PDF) Marked with official reporter pages for citation.
Source of the text: govinfo.gov (the court's filed opinion) — https://www.govinfo.gov/app/details/USCOURTS-ca2-23-00350. This page summarizes the decision in plain language; the court's own words are in the opinion below.