The underlying dispute involves nine current and former employees of Koran Landscape Service Inc. who sued the company, owner Bill Koran, and Brad Wine in March 2019, alleging failures to pay overtime under the FLSA and New York Labor Law, failures to pay additional wages for days exceeding ten hours under the New York Minimum Wage Act, and failures to provide proper wage statements under New York Labor Law. The complaint alleged violations stretching back to 2013.
After a June 2025 jury trial in the Eastern District of New York, the jury returned verdicts in favor of all plaintiffs, generally finding defendants failed to provide appropriate overtime compensation and appropriate wage and compensation statements. The dispute before Judge Joanna Seybert on post-trial motions centered on four of those plaintiffs — Carlos Humberto Chavez, Casto Cuadra, Jose Lidio Reyes Granados, and Jose Efraim Granados — whose verdict sheets included damages for 2019, a period either not covered or affirmatively contradicted by the complaint.
The complaint alleged Chavez and Cuadra left Koran Landscaping in December 2018, but both testified at trial that they continued working there until May 2019 and, on cross-examination, said the complaint's departure timelines were inaccurate. Reyes Granados testified he was still employed at the time of trial; Efraim Granados said he worked there until 2021. All four also testified that the landscaping season did not typically begin until March 15 or 20, which undercut any 2019 damages for Reyes Granados and Efraim Granados even though the complaint alleged they were still employed as of its March 14, 2019 filing date.
Judge Seybert held that the continuing-violation doctrine does not apply to FLSA claims, under which each pay period gives rise to a separate cause of action. Because the plaintiffs never moved to amend the complaint and the parties never explicitly or impliedly consented to trying the 2019 claims, the 2019 damages — $2,240 for Chavez, $4,590 for Cuadra, $4,860 for Reyes Granados, and $5,130 for Efraim Granados — were awarded on unpleaded causes of action and cannot stand. The court rejected the plaintiffs' argument that the jury's 2019 liability findings were simply credibility determinations entitled to deference, holding that testimony about 2019 work has no bearing on whether plaintiffs may collect damages for claims never pleaded.
The $5,000 wage-statement penalty awarded to each of the four plaintiffs survived intact. Defendants argued those figures should be reduced or eliminated to the extent they reflected 2019 work, but their motion contained only a single-sentence assertion on the point, cited no supporting case law, and failed to identify which portions of the penalty amounts related to 2019. The court declined to disturb the jury's wage-statement findings on that record.
The order is conditional: the four plaintiffs have until March 12, 2026 to accept the reductions. If they do not, the court will schedule a new trial on the affected claims.