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Team Washington Inc. Domino's Delivery Driver Dispute

Team Washington, Inc., and its owner, Mary Lynne Carraway operate approximately 76 Domino’s Pizza stores in and around Washington, D.C. The plaintiff, a former Domino’s Pizza delivery driver who seeks to represent all Team Washington, Inc. delivery drivers in federal court, claims that Team Washington, Inc. broke the law by underpaying its delivery drivers for automobile expenses and by failing to properly pay its delivery drivers for overtime hours worked.

Like many other similar cases around the county, the lawsuit alleges that the company enacted and enforced reimbursement policies that resulted in their delivery drivers making less than minimum wage for the hours they work after accounting for expenses.

Federal law prohibits employers from paying employees less than minimum wage, either outright or by improperly shifting costs onto employees.

If you are a delivery driver who works or who has worked at this or any other pizza company around the country, contact our firm to find out if you might be owed unreimbursed expenses. We can explain the process you can go through to get those expenses back. Give us a call at (513) 428-8689 or fill out the contact form on this website for a free consultation.

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Case Details



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 at the IRS standard business mileage rate (currently $.585 per mile) when the employer does not collect records of the drivers’ actual expenses and reimburse based on those records.

Even if the company is permitted to reimburse based on an “approximation,” as we expect the defendants will argue, the plaintiff alleges that the Team Washington, Inc. Domino’s stores have failed to “reasonably approximate.”

Plaintiff alleges that this practice violates the federal Fair Labor Standards Act and D.C. Wage law, D.C. Code §32-1003 et seq. and D.C. Code §32-1302 et seq.

 Failure to Pay Overtime Wages

Second, the plaintiff alleges that the company did not properly pay its employees the required time and a half overtime wages when employees worked in excess of 40 hours per week.

Plaintiff alleges that this practice violates the federal Fair Labor Standards Act and D.C. Wage law, D.C. Code §32-1003 et seq. and D.C. Code §32-1302 et seq.

 Unjust Enrichment

In addition, the plaintiff asserts a claim for unjust enrichment. He alleges that the Team Washington, Inc. Domino’s 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 06-01-2022

Lawsuit filed against Team Washington, Inc. and Mary Lynne Carraway

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