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Riggins v. P. I. & I. Motor Express Inc.

United States District Court, N.D. Alabama, Southern Division

April 26, 2018

RONALD RIGGINS, Plaintiff,
v.
P. I. & I. MOTOR EXPRESS, INC., et al., Defendants.

          MEMORANDUM OPINION

          KARON OWEN BOWDRE CHIEF UNITED STATES DISTRICT JUDGE

         This fraud and breach of contract case comes before the court on Plaintiff Ronald Riggins's “Motion to Dismiss P. I. & I.'s Counterclaims” (doc. 20). The court will GRANT IN PART AND DENY IN PART Mr. Riggins's motion to dismiss the counterclaim.

         The court will GRANT the motion as to P. I. & I.'s unjust enrichment claim because P. I. & I. consents to its dismissal. The court will DISMISS WITH PREJUDICE P. I. & I.'s unjust enrichment allegation. However, for the reasons discussed below, the court will DENY Mr. Riggins's motion to dismiss the counterclaim in all other respects.

         STANDARD OF REVIEW

         Courts evaluate a Rule 12(b)(6) motion to dismiss a counterclaim using the same standard as a motion to dismiss a complaint. Generally, the Federal Rules of Civil Procedure require only that a counterclaim provide “‘a short and plain statement of the claim' that will give the [counterclaim defendant] fair notice of what the [counterclaim plaintiff's] claim is and the grounds upon which it rests.” Conley v. Gibson, 355 U.S. 41, 47 (1957) (quoting Fed.R.Civ.P. 8(a)). A counterclaim plaintiff must provide the grounds of his entitlement, but Rule 8 generally does not require “detailed factual allegations.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley, 355 U.S. at 47). It does, however, “demand[ ] more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal 556 U.S. 662, 678 (2009). Pleadings that contain nothing more than “a formulaic recitation of the elements of a cause of action” do not meet Rule 8 standards nor do pleadings suffice that are based merely upon “labels or conclusions” or “naked assertions” without supporting factual allegations. Twombly, 550 U.S. at 555, 557.

         The Supreme Court explained that “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.'” Iqbal, 556 U.S. at 678 (quoting and explaining its decision in Twombly, 550 U.S. at 570). To be plausible on its face, the counterclaim must contain enough facts that “allow[ ] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678.

         BACKGROUND

         A. Facts

         The court takes the facts as alleged in P. I. & I.'s countercomplaint (doc. 11) as true. P. I. & I. provides truck drivers for U.S. Steel's plant in Fairfield, Alabama. Mr. Riggins was, for a time, one of those truck drivers.

         In 2010, Mr. Riggins and P. I. & I. entered into a contract. Mr. Riggins promised to haul steel and related materials for U.S. Steel in Fairfield. In exchange, P. I. & I agreed to pay Mr. Riggins based on “shipping logs and hourly time records” that Mr. Riggins submitted to P. I. & I. reflecting the time he worked at U.S. Steel's plant.

         Under the arrangement, Mr. Riggins submitted his shipping logs and hourly time records to P. I. & I., and P. I. & I. forwarded them to U.S. Steel. U.S. Steel then paid P. I. & I. for Mr. Riggins's work, and, finally, P. I. & I. paid Mr. Riggins. Mr. Riggins worked for P. I. & I. and U.S. Steel from May 2010 through March 2015.

         On March 9, 2015, U.S. Steel told P. I. & I. that Mr. Riggins could no longer work at the Fairfield plant. U.S. Steel told P. I. & I. that Mr. Riggins had been falsifying his shipping logs and time records, leading to U.S. Steel's overpaying P. I. & I.

         P. I. & I. initially maintained that Mr. Riggins's records-and U.S. Steel's payments to P. I. & I. under their contract-were proper. However, in a November 2016 meeting, U.S. Steel told P. I. & I. that it overpaid P. I. & I. $350, 000 between January 2012 and December 2014.[1]And P. I. & I. learned that U.S. Steel had been “track[ing] the logistics of all deliveries entering and leaving its Fairfield plant including the number of hours each owner operator spent within the Fairfield plant.” (Doc. 11 at 9). This evidence convinced P. I. & I. that Mr. Riggins falsified the documents.

         B. P.I. & I.'s Counterclaim Allegations

         P. I. & I. alleges that Mr. Riggins committed fraud, breached their contract, and unjustly enriched himself by his actions. As noted above, P. I. & I. consents to dismissal of its unjust enrichment allegation.

         As to fraud, P. I. & I. alleges that Mr. Riggins knowingly and intentionally submitted falsified time logs and shipping documents to U.S. Steel. P. I. & I. adds that Mr. Riggins owed it a duty to report these logs and documents accurately under their contract. P. I. & I. states that it relied on those documents in requesting and receiving payment from U.S. Steel. In addition, P. I. & I. states that ...


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