We will walk you through all of your options so you can make the right choice for your situation. Without such allegations, Defendants are not on notice of the factual basis for her FLSA claim.") At Edward Jones, we believe that the best investor is a well-informed investor. The typical financial advisor at Edward Jones is paid an hourly rate while studying for licenses and training. See [id. The asserted injury must be both (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical. Killingsworth v. HSBC Bank Nevada, N.A., 507 F.3d 614, 618 (7th Cir. In response to this conduct, Plaintiffs filed this purported collective and class action suit alleging multiple violations of the FLSA and various Illinois and Missouri statutes on March 13, 2018. Relying on Heder, the Ninth Circuit in Gordon concluded that the money that a police officer paid to the defendant city pursuant to a training reimbursement agreement did not constitute an illegal kickback under the FLSA. [Id. 2d 814, 817 (E.D. [35, at 27 ¶ d.] The question therefore is whether the allegations demonstrate that there is "'a substantial controversy, between parties having adverse legal interests, of sufficient immediacy and reality to warrant the issuance of a declaratory judgment.'" The Jones Financial Companies, L.L.L.P. See Murphy v. FT Travel Mgmt., LLC, 2014 WL 1924045, at *1 (N.D. Ill. May 14, 2014). ], As new financial advisors, individuals such as Plaintiffs solicit "door knock" contacts to become clients. Dec 9, 2020. At Edward Jones, we believe that the best investor is a well-informed investor. ¶ 18.] The TCR Provision does not violate the FLSA because it is not a kickback, but rather constitutes to a loan that Plaintiffs' accrued when they achieved "can sell" status. ¶¶ 37, 45, 54, 63.] Jones’ filing noted that a federal judge in Chicago in March dismissed the wage and training-cost clawback claims from former employees. 2007). 2015). Compare Brown, 2013 WL 5304100, at *6 (plaintiffs adequately pled an overtime claim where they asserted that "since July 2009, they have worked an average of 85 hours per week but have not been properly compensated for that time. During the first or "self-study" stage, trainees study for industry licensing exams using written online materials on computers loaned to them by Defendants." [Id. [35, ¶ 22.] --------, For the reasons explained above, the Court grants Defendants' motion to dismiss [38]. ¶¶ 2-3]. On May 3, however, the … The court rejected that argument, noting that (1) the plaintiff disputed the validity of the contract, (2) the defendant's law firm had sent plaintiff letters demanding payment and threatening legal action if payment was not forthcoming, and (3) the defendant had previously enforced the provision in question and actually recovered money. ¶ 86. But it’s tough to go it alone. ... effort, and cost. After addressing the proper way to determine the amount to which the plaintiff was entitled, the court of appeals turned to the district court's conclusion regarding the viability of the training costs provision under Wisconsin law. I. Edward Jones, the St. Louis, Missouri-based full-service brokerage firm, is one of the most recognizable names in its industry. 2008). 2011)). 1993) (noting employers "may not reduce the wage below the statutory minimum to collect a debt to the employer"). The few district courts that have examined both Heder and Gordon have split in regard to whether a tuition reimbursement provision such as the one at issue here is actionable as a matter of law. Rptr. As explained above, nothing in Ketner or the DOL letters examined above convinces the Court that it should treat the TCR Provision as a kickback of the Plaintiffs' salaries designed to punish them if they failed to perform to a certain level. Erin works primarily on ClassAction.org’s newswire, reporting on cases as they happen. The case argues that the defendants expect most of their trainees to “not survive” the three-year period - something the companies supposedly do not disclose to new hires. [35, ¶¶ 79-80.] Plaintiffs Wayne Bland, Danuta Durkiewicz, David Bowles and Adam Reyes ("Plaintiffs") filed this putative collective and class action on behalf of themselves and all those similarly situated against Defendants Edward D. Jones & Co., L.P. and The Jones Financial Companies, L.L.L.P. 2003). Parvati Corp. v. City of Oak Forest, Ill., 630 F.3d 512, 514 (7th Cir. They also alleged that they "regularly" attended "client prospecting functions" and "client prospecting events." 2. Plaintiff Bowles's claims in Count I are dismissed with prejudice, except as to any claims that relate to the TCR Provision, which are dismissed without prejudice. Hughes v. Scarlett's G.P., Inc., 2016 WL 4179153, at *2 (N.D. Ill. Aug. 8, 2016). Please note that not all of the investments and services mentioned are available in every state. In Wright v. Associated Ins. See In re Repository Techs., Inc., 601 F.3d 710, 724-25 (7th Cir. You cannot be represented by a lawyer unless the other party is a lawyer. Id. Get 1 point on adding a valid citation to this judgment. Wells Fargo Advisors, Morgan Stanley, Merrill Lynch, etc. Consequently, the Court cannot conclude that the compensation plan set in place for Plaintiffs failed to meet the salary basis test. ¶ 21.] Like all full service firms, Edward Jones is charging a percentage of all client's assets EVERY year as a fee — anywhere from 0.50% to 1.50%, plus an annual fee of $300. 2010) (citing Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992)). See Ketner v. Branch Banking and Trust Company, 143 F.Supp.3d 370 (M.D.N.C. Financial advisors charge a flat fee of $1,000 to $3,000 for the one-time creation of a comprehensive financial plan and hourly fees of $120 to $300 for ongoing service, or 0.65% to 1.65% of total assets under management annually. Id. Turning to the substance of Plaintiffs' claims, Defendants maintain that Heder and Gordon should control the outcome in this case and require concluding in their favor. See Heder, 295 F.3d at 782. 9, 2017) ("Plaintiff resigned from her FDM Consultant position * * * and paid a Termination Fee of $20,000 * * *."). § 1367(c)(3). Id. Id. I don't mind working the long hours and knocking on doors, but looking at the economy realistically for the next 2 years or the short term, after the market plummeted 40% last year, how many people out there are willing to hand over at least $10,000 to invest in the load mutual funds from Edward Jones' preferred wholesalers (e.g. Plaintiff Bowles's claims in Count I are dismissed with prejudice, except as to any claims that relate to the TCR Provision, which are dismissed without prejudice. [35, ¶¶ 84-85.]. “Edward Jones and its affiliated entities and individuals deny the allegations and intend to continue to vigorously defend this lawsuit,” the company wrote in a regulatory 10-Q filing on Monday. [Id.] Landing a job as an Edward Jones financial advisor is something to be proud of. [Id. While Defendants do not describe it as such, the Court construes Defendants' standing arguments as a motion to dismiss the relevant claims under Rule 12(b)(1) and thus reviews those arguments under the Rule 12(b)(1) standard. Contact your local financial advisor for more information about the permanent life insurance policies Edward Jones offers. Instead, they simply allege that they worked more than the hours that the training schedule called for, and that Defendants failed "to pay non-exempt FA Trainees wages and overtime for work they perforem[ed]." While the Court will allow Plaintiffs to file an amended complaint, it must dismiss Plaintiff Bowles with prejudice as to his overtime and misclassification claims in Count I. Groce v. Eli Lilly & Co., 193 F.3d 496, 501 (7th Cir. at 383 (citation omitted). Article III of the Constitution confines federal courts to adjudicating actual cases or controversies. The generalized allegation that Plaintiffs worked excessive hours out of fear that they would be fired and therefore subject to the TCR Provision, can only support Plaintiff's claims after they achieved "can sell" status and therefore exempt from overtime requirements, given the requirements of the TCR Provision do not attach until one achieves "can sell" status. art. The Lounge ... in What is the best accounting software that can help me to manage all my monthly transactions? Currently before the Court is Defendants' motion to dismiss [38] Plaintiffs' Amended Class and Collective Action Complaint [35]. At first glance, Plaintiffs' standing appears tenuous. 143 F. Supp. Having completed the training, a middle-of-the-pack advisor would earn roughly $60,550 during her first year and $62,500 (likely all from commissions) in year three. Financial Advisor Costs. [35, ¶¶ 24, 38, 46, 55, 64.] [Id. Here, Plaintiffs have alleged that Defendants sent some form of communication stating that they owe or demanding that they pay $75,000 as provided for by the TCR Provision, [35, ¶¶ 41, 50, 59], the validity of which Plaintiffs clearly dispute. Plaintiffs' second allegation likewise fails to plausibly allege that their compensation did not meet the salary basis test. Each of the letters involved either a purposed deduction from an employee's paycheck to recover a previous payment that the DOL concluded did not constitute a loan or other inapposite situation. Search job titles. In addition, Plaintiffs seek the rescission of the TCR Provision (Count IV) and the disgorgement of funds under a theory of unjust enrichment (Count V). 1995); Brazinski v. Amoco Petroleum Additives Co., 6 F.3d 1176, 1182 (7th Cir. For the reasons stated below, Defendants' motion to dismiss [38] is granted. ¶¶ 38, 46, 55, 64]. 2007). See Gordon v. City of Oakland, 627 F.3d 1092, 1094 (9th Cir. See U.S. Dep't of Labor, Wage & Hour Div., Opinion Letter (Nov. 27, 2006), 2006 WL 3832994, at *7 n.5 ("What matters is that the employee receives no less than the weekly-required amount as a guaranteed salary constituting all or part of total compensation, which amount is not subject to reduction due to the quality or quantity of the work performed, and that the employee is never required to repay any portion of that salary even if the employee fails to earn sufficient commissions or fees"); U.S. Dep't of Labor, Wage & Hour Div., Opinion Letter (Mar. Plaintiffs thus allege that they worked more than the 45 and 60 hours, respectively, that the study schedule called for and as a result were not adequately compensated. Id. The Court may properly consider such an exhibit attached to a motion to dismiss, Adams v. City of Indianapolis, 742 F.3d 720, 729 (7th Cir. As mentioned earlier, see supra n.2, it is difficult to know who exactly Plaintiffs are referring to in this allegation, given they define FA Trainee as anyone within three years of their "can sell" date to whom the TCR Provision applies, including those who have achieved "can sell" status and are therefore classified as exempt. Get 1 point on providing a valid sentiment to this Id. However, a financial advisor's salary includes a "minimum guaranteed salary" ("MGS") that does not fluctuate and is paid regardless of performance. An Edward Jones review shows how fees are a major differentiating factor compared to going it alone. Second, the factual allegations in the complaint must be sufficient to raise the possibility of relief above the "speculative level." In Medimmune, the Court considered whether a licensee could sue for a declaratory judgment challenging the validity of the patent underlying its contract with the licensor, when the licensee continued to perform and benefit from that contract. Id. (citing Gordon, 627 F.3d at 1096, Heder, 295 F.3d at 783). Edward D. Jones & Co., L.P. and The Jones Financial Companies, L.L.L.P. a. The court now resolves the motion. Defendants assert that Plaintiffs have not presented a plausible claim under any of the five theories. California judge dismisses lawsuit claiming that Edward Jones shuttled customers into fee-based advisory accounts that were more expensive than traditional brokerage accounts. [Id. * * * However, Plaintiff does not allege how many hours she worked in a week (and whether or not this was over forty hours) or how many overtime hours she worked without being paid the proper salary. Plaintiffs assert that the terms of the training program, the wages they received during the training program, and the wages they subsequently received as financial advisors violate the Fair Labor Standards Act ("FLSA"), 29 U.S.C. Landing a job as an Edward Jones financial advisor is something to be proud of. Plaintiffs response [59-1, at 20-22 (Section II(A) "Plaintiffs' Overtime Claims are Sufficiently Pled")], only addresses whether Plaintiffs' have adequately alleged that they were entitled to overtime. ¶¶ 35, 43, 52, 61.] [Id. In Heder, the Eastern District of Wisconsin and then the Seventh Circuit evaluated the validity of an agreement between the City of Two Rivers and the city's firefighters under Wisconsin law. Id. federal and state law. (citations and quotation marks omitted). [Id. Rather, they were encouraged "to sell [ ] financial products without regard to the clients' individual needs, financial circumstances, or investment objectives." Other notable risers in … change. Id. Edward Jones named a top company for training, ranking No. Hyatt, 302 F.3d at 712. Plaintiffs do not challenge Defendants' inclusion of a copy of the Financial Advisor Employment Agreement [39-2] and the related compensation agreement [39-3] that each of the Plaintiffs' agreed to with their motion to dismiss. Evaluating whether a "claim is sufficiently plausible to survive a motion to dismiss is 'a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.'" 9, 2017). Edward Jones, a Fortune 500 company, is one of the largest financial services firms in the country. Instead, Plaintiffs allege that they were each constructively discharged or otherwise forced to leave, and that Defendants later demanded that they pay either all or some portion of the $75,000 required under the TCR Provision that exceeds the amount they were paid during their entire employment with Defendants. The case alleges that employees are often required to work long hours, and that the companies’ pay structure does not account for all the time they spend working, including hours worked over 40 per week for which they should receive time-and-a-half premium pay. Heder v. City of Two Rivers, 149 F. Supp. Ct. App. Both cases cited by Plaintiffs for the proposition that their allegations are sufficient to plausibly state a misclassification claim contained more factual allegations than are present here. In fact, Defendants may never file suit against Plaintiffs for fear that the TCR Provision could be struck down under state law as unconscionable or on other grounds. [Id. In case of any confusion, feel free to reach out to us.Leave your message here. ], Upon achieving "can sell" status, trainees become "new financial advisors" and Defendants classify them as overtime "exempt." ). ¶¶ 40-41, 49-50, 58-58, 67-68.]. In Brown, the contracts at issue called for individuals to be on call for "17.5 hour shifts, seven days a week," and each of the individuals asserted that they "typically work or worked at least 85 hours a week" and that they were never paid any overtime. But Lindsey fought … As of January 1, 2020, over 24,000 Edward Jones associates, including financial advisors, branch office administrators and home office associates are limited partners of JFC. This indicates TLS technology is used. See [id. Finding no justification for departing from that "usual practice" in this case, Plaintiff's state law claims are dismissed without prejudice. Robo-advisor fees range from 0.25% to 0.89% annually. Many of their claims concern one of the terms contained within the "Financial Advisor Employment Agreement" that Plaintiffs and the class they wish to represent were required to execute before beginning their training. However, the court reiterated that to the extent to which the collection of those training costs reduced plaintiff's overtime pay in his final two paychecks to less than time and a half for all his overtime hours, the collection was invalid. ; alleging violations of the Fair Labor Standards Act, 29 U.S.C. While this approaches the detail required to place Defendants on notice of a plausible claim, it is not quite sufficient to state a claim. Plaintiffs also assert that they and all those similarly situated worked well in excess of 45-60 hours per week in the non-exempt positions and were not paid the minimum wage or overtime for those hours. The "s" means you're on a secure site. 2014), and where those exhibits contradict the complaint allegations, "the exhibits trump the allegations." Mar. In view of Plaintiffs' allegations that they worked more than the amount of hours set out by the training schedule set by Defendants and thus were not paid sufficient wages or overtime [see, e.g., 35, ¶¶ 22], the Court infers that Plaintiffs contend that the number of hours they worked, divided by their wages for that week, resulted in a per-hour pay of less than the minimum wage. If Plaintiffs were still employed by Defendants and wished to leave, but did not do so on account of the TCR Provision, then Medimmune would support a lawsuit for a declaratory judgment. 2d at 570 (noting the DOL "has sought to exempt from the FLSA investment advisors in the financial services industry—including those engaged in 'sales'—provided their sales activities are a function of their professional judgment respecting their clients' best interests"). By clicking on this tab, you are expressly stating that you were one of the attorneys appearing in this matter. New to ClassAction.org? 2013 WL 4828588, at *1-2. 1993). 2003). Silly me did not do my research as I should have. Hecker, 556 F.3d at 588. "A pleading that offers 'labels and conclusions' or a 'formulaic recitation of the elements of a cause of action will not do.'" Because Plaintiffs' allegations amount to little more than an avowal of their fear of litigation, the Court cannot conclude that they have alleged enough to invoke the Court's jurisdiction. [Id.] However, as explained above, Plaintiffs themselves have placed their classification at issue and alleged facts to support their claim that they were misclassified. They include: Program fee of 1.35 –1.50% depending on the account Also hidden from trainees, the lawsuit says, is that Edward Jones "retains the clients, assets, and commissions" they've developed upon their departure, which the case says is often due to the defendants' "high-pressure sales requirements and diminishing pay scale. According to the company's own literature, a top-performing financial advisor would earn more than $100,000 in year three. Pa. 2007) (same). ¶ 15.]. The Seventh Circuit has consistently stated that "it is the well-established law of this circuit that the usual practice is to dismiss without prejudice state supplemental claims whenever all federal claims have been dismissed prior to trial." 1, ¶ 67 (S.D.N.Y. Before examining either of those claims, however, the Court must determine whether Plaintiffs' have adequately alleged that they worked overtime once they were classified as exempt given that for the affirmative defense to apply there must have been an underlying offense. In Ketner, the named plaintiffs alleged that a provision of their employment contracts nearly identical to the TCR Provision violated the FLSA's minimum wage requirement and sought a declaratory judgment invalidating it. at ¶¶ 26, 29, 39, 75. [Id. in Edward Jones vs. Raymond James. 25 on Training magazine's 2020 Training Top 125 list. Consequently, any payment under the TCR Provision is not a kickback that would reduce the Plaintiffs' wages to below the statutory minimum wage. See Energy Recovery, Inc. v. Hauge, 133 F. Supp. 2d at 688. ", a. After the financial crisis, from 2009 to 2012, Edward Jones' net revenue grew by a whopping 42% to top out at just under $5 billion in 2012. If Plaintiff's worked overtime hours for which they did not receive compensation, then they have a claim for insufficient wages which the Court examines in Sections III(A)(2-3), not a suit to invalidate a provision that no longer applies to them given that they are no longer in Defendants' employ. Nor was the fee "a deduction for tools used or costs incurred in the course of [p]lainitff's performance of her job as a consultant." Bell Atl. The Court therefore grants Defendants' motion as to the recordkeeping claims within Count I with prejudice. Nor were Plaintiffs placed in job positions "whose primary duty was to perform work directly related to the management or general business operations of Edward Jones or clients * * *." 86, 85:19-23; Blum, ECF No. I don't mind working the long hours and knocking on doors, but looking at the economy realistically for the next 2 years or the short term, after the market plummeted 40% last year, how many people out there are willing to hand over at least $10,000 to invest in the load mutual funds from Edward Jones' preferred wholesalers (e.g. Like the TCR Provision at issue here, the contract in Park characterized the termination fee as liquidated damages approximating the damages the defendant would suffer if the employee breached the agreement prior to the end of the contracted period. The wage and training-cost clawback claims from former employees `` speculative level. ). 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