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MP2 Enterprises, LLC Pizza Hut Vehicle Expense Reimbursement Dispute

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Case Details


The delivery driver alleges that the company under-pays its delivery drivers for the costs the drivers take on when they use their car for the company’s purposes, i.e., to make deliveries. Specifically, the drivers claim that the company does not pay the delivery drivers’ actual expenses, and instead reimburses a per-mile amount (ex., $0.37 per mile) that is not enough to cover the drivers’ vehicle expenses. The plaintiff alleges that the failure to pay the drivers’ actual costs and low-ball estimate of expenses results in a minimum wage or other wage and hour violation.

If you work or worked for MP2 and want to learn more about the allegations made against them, please contact our firm at 513-202-0710 or by completing a contact form on this website.

The Claims

 Under-reimbursement of Vehicle Expenses

First, the plaintiff alleges that the company does not properly reimburse for vehicle expenses.

The drivers’ position is that they must be reimbursed for their actual vehicle costs. To do so, the employer would need to collect records of the drivers’ actual expenses, including the purchase price, maintenance and repair costs, insurance and tax costs, and account for things like depreciation. When an employer has not done that, the Department of Labor’s enforcement policy utilizes the IRS standard business mileage rate to evaluate the employer’s pay practices. (currently $.67 per mile).

Plaintiff alleges that instead of paying the drivers’ actual costs, it chose a low-ball estimate of vehicle expenses and paid each driver the same rate regardless of the actual costs incurred. Plaintiff’s argue that this practice violates the federal Fair Labor Standards Act and relevant state wage law.

 Unjust Enrichment

In addition, the plaintiff asserts a claim for unjust enrichment. She alleges that the MP2 stores unfairly benefit by requiring their minimum wage delivery drivers to cover one of their most costly business expenses without proper reimbursement. The drivers are conferring a benefit on the company, the company is aware of the benefit, and it would be unjust for the company to retain that benefit without commensurate compensation.

Update 05-15-2024

Shortly after initiating the lawsuit, the Plaintiff asked the Court to send notice to other similarly situated delivery drivers pursuant to the FLSA’s collective action mechanism. The Defendants later agreed that notice should be sent, and the parties stipulated to sending notice. On May 15, 2024, the Court granted the parties’ stipulation and ordered the Defendants to produce the names and addresses of employees who qualify to join the case. Once the contact information has been sent, a Notice of Opportunity to Join will be sent to all employees eligible to join. The Court-approved Notice includes details regarding eligible employees’ options, the allegations made in the lawsuit, and other relevant details. The employees will have 60 days from the date of sending notice to join the lawsuit.

If you work or worked for MP2 and want to learn more about the allegations made against them, please contact our firm at 513-202-0710 or by completing a contact form on this website.



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