Woodford v. HRG Management, LLC

Syllabus

The plaintiff, who had been employed as a server and hostess at restaurants owned and operated by the defendants, appealed from the trial court's judgment granting the defendants' motion to strike her putative class action complaint. The plaintiff claimed, inter alia, that the defendants had improperly deducted tip credits from her earnings and paid her and other similarly situated employees less than the minimum wage for the performance of nonservice work under the applicable wage regulations (§ 31-62-E3 et seq.) in effect in 2015. Held: The trial court properly granted the defendants' motion to strike the plain- tiff's complaint, as this court had twice previously determined that there was no private cause of action pursuant to statute (§ 31-68 (a)) for violations of the recordkeeping requirements in § 31-62-E3 of the 2015 regulations, the complaint was legally insufficient as it was not premised on the applicable wage regulation (§ 31-60-2), as required under the legislature's amendment (P.A. 22-134) to the statute (§ 31-60) governing actions for violations of wage laws, P.A. 22-134 did not retroactively take away the plaintiff's cause of action, the application of P.A. 22-134 to the plaintiff's claims did not vio- late due process, and, because this court's decision in the companion case of Farias v. Rodriguez (238 Conn. App. 287) thoroughly resolved the plaintiff's claims, this court adopted the reasoning and conclusions in that decision. Argued November 13, 2025—officially released March 31, 2026