UNITED STATES DISTRICT COURT
DISTRICT OF
NEW MEXICO

COCA COLA BOTTLING COMPANY OF SANTA FE, INC.,

 

 

 

 

 

Case No. CIV 03-1440 WJ/RHS

 

 

Plaintiff,

 

 

v.

 

 

THE CITY OF SANTA FE,

 

 

 

Defendant.

 

 

 

MEMORANDUM IN SUPPORT OF MOTION TO DISMISS

OR, IN THE ALTERNATIVE, TO STAY

 

            Plaintiff Coca Cola Bottling Co. of Santa Fe (“Coca Cola”) seeks to relitigate in this Court the legality of the Santa Fe Living Wage Ordinance (“the Ordinance”), despite the fact that its legality was fully litigated and recently upheld in the First Judicial District of New Mexico in New Mexicans for Free Enterprise et al. v. City of Santa Fe, No. D-0101-CV-2003-468 (“the state court proceeding”).  New Mexicans for Free Enterprise (“NMFE”)[1] and the Santa Fe Chamber of Commerce (“the Chamber”) brought the state court proceeding over a year ago on behalf of their members, including Coca Cola.[2]  In the state court proceeding, NMFE and the Chamber attacked the ordinance on grounds similar to those that Coca Cola now asserts in this Court.  The state court proceeding occupied more than a year of intensive litigation, including a full bench trial.  It resulted in a final judgment upholding the Ordinance against all attacks and the Chamber and NMFE recently announced their intent to appeal.  Accordingly, the validity of the Ordinance is under thorough review within the New Mexico court system as a result of the litigation brought on behalf of Coca Cola and other Santa Fe businesses.   

The background of this duplicative federal suit is no secret.  In late February, 2003, two weeks before the state court proceeding began, NMFE’s lawyer announced that NMFE intended to file suit in both state and federal courts.[3]  On December 18, 2003, shortly before the Ordinance was to take effect, NMFE’s executive director announced the filing of this case, indicating that while the plaintiffs intended to pursue the state case, they thought they might have a better chance of winning an injunction in federal court.[4]  See infra “Procedural History,” at pp. 4-8.  Plaintiff in this case, however, is not NMFE or the Chamber, but Coca Cola Bottling of Santa Fe.  Coca Cola’s litigation function is apparently to provide the Ordinance’s opponents a different name on the caption in the hope that it will be perceived as independent of the plaintiffs in the state case and, accordingly, not bound by its result.

Coca Cola and the state court plaintiffs opened this second front under the cover of federal constitutional claims that NMFE and the Chamber calculatedly refrained from pleading in their state court proceeding.  If Coca Cola’s federal claims were substantial and if it were genuinely independent of the state plaintiffs, the maneuver might pass a blush test.  But Coca Cola’s federal claims are not colorable.  Furthermore, not only has Coca Cola’s state claim been decided in a state district court, it will soon be decided authoritatively by New Mexico’s appellate courts, whose interpretation of state law will be binding on federal courts.

Coca Cola’s federal constitutional claims (Counts 2-5), such as they are, arise under the Fourteenth Amendment to the United States Constitution and consist of allegations that the Ordinance violates equal protection, substantive due process, vagueness, and the Privileges or Immunities Clause.  Notably, the state constitutional equivalents of all but the privileges or immunities clause were litigated and rejected in the state court action.

            Coca Cola’s pendent state claim (Count 6) charges that enactment of the Ordinance exceeded Santa Fe’s home rule powers under Article X, § 6 of the New Mexico Constitution because the Ordinance amounts to a local law “governing civil relationships.”  Compl. ¶ 98-99.   This question of first impression under New Mexico law was a central issue in the state court lawsuit and, as noted above, was resolved in favor of the City and against the organization of which Coca Cola is a member. 

By this motion, Defendant the City of Santa Fe (“the City”) respectfully requests that this Court dismiss Coca Cola’s federal claims, under Rule 12(b)(6), for failure to state claims.  The Court should dismiss them because Coca Cola’s federal claims, as explained below at Point I, not only find no support in federal decisional law but have been rejected consistently and repeatedly by the Supreme Court and federal appellate courts.

As to Coca Cola’s sole state law claim:  First, if this Court agrees that Coca Cola’s federal claims are subject to dismissal, then the Court should dismiss the state law claim pursuant to 28 U.S.C. § 1367(c) as there would no longer be a proper basis for supplemental jurisdiction.  Second,  even if the Court were to conclude that Coca Cola’s federal law claims do not warrant dismissal, it should nevertheless dismiss Coca Cola’s pendent state law claim because it presents a “complex” issue of state law that, under 28 U.S.C. § 1367(c), is not an appropriate subject for supplemental jurisdiction.  Third, even if this Court were to conclude that Coca Cola’s federal claims are not subject to dismissal, and that 28 U.S.C. § 1367(c) does not require dismissal of the pendent state claim, then this Court should stay consideration of the state claim — and of this lawsuit — pursuant to the abstention principle outlined in Thibodaux v. Louisiana Power and Light Co., 360 U.S 25 (1959), pending resolution of this “decisive issue[ ] of state law” by the New Mexico appellate courts.  See infra Points II-III.

 

PROCEDURAL HISTORY

On February 27, 2003, the Santa Fe City Council voted to enact Santa Fe City Ordinance 2003-8 — the Santa Fe Living Wage Ordinance.  The Ordinance amended an earlier law enacted in 2002, Santa Fe City Ordinance 2002-13, which had established an $8.50 per hour minimum wage applicable to employees of businesses receiving certain contracts or subsidies from the City, as well as to employees of the City itself.  The new Ordinance, which had an effective date of January 1, 2004, extended the $8.50 minimum wage to employees at businesses in Santa Fe employing 25 or more persons.  Under the Ordinance, the minimum wage will increase to $9.50 per hour on January 1, 2006, and to $10.50 per hour on January 1, 2008.  See Ordinance § 28-1.5(B).

The Ordinance was the product of a fifteen month public process of debate and fact-gathering by the citizens of Santa Fe and the Santa Fe City Council.  Enacted by he City Council pursuant to Santa Fe’s broad constitutional and statutory powers to protect the public health, welfare, and safety, the Ordinance is designed to help ensure a decent standard of living for workers in the Santa Fe community.  See Ordinance § 28-1.2 (Legislative Findings).

Santa Fe is one of four American cities ― the others are Washington, D.C., Madison, Wis., and San Francisco, Calif. ― that, in recent years, have enacted citywide minimum wage ordinances to help local low-wage workers make ends meet.  See District of Columbia Code § 32-1001 et seq.; Madison Gen’l Ords. § 3.45; San Francisco Admin. Code ch. 12R.  More than 120 other cities and counties across the country have enacted narrower living wage ordinances that establish higher minimum wages for businesses receiving contracts or subsidies from local governments.  See Association of Community Organizations for Reform Now (ACORN) Living Wage Resource Center, Living Wage Wins, at http://www.livingwagecampaign.org.

As the Ordinance moved forward in the City Council, Certain members of the business community, including the Chamber and NMFE — a business group established for the sole purpose of fighting the Ordinance — began planning a coordinated legal strategy to challenge it in both state and federal court.[5]  On the day that the Ordinance was enacted, their attorney announced to the media that “he plan[ned] to file a motion for preliminary injunction in state District Court early next week after reviewing the new law, ‘to keep the ordinance from going into effect,’ followed by another suit in federal court.”  John T. Huddy, “Living Wage” Headed to Court, Albuquerque Journal, Feb. 28, 2003, at 1.

Two weeks later, on March 10, 2003, NMFE, the Chamber, and several named individual Santa Fe businesses filed a lawsuit in Santa Fe County District Court challenging the Ordinance.  The state court lawsuit, New Mexicans for Free Enterprise v. City of Santa Fe, No. D-0101-CV-2003-468, challenged Santa Fe’s authority under New Mexico’s constitutional home rule provision to enact a minimum wage law, and raised eight other state law claims including equal protection, due process, vagueness, and preemption under the New Mexico Minimum Wage Act.  See Complaint, New Mexicans for Free Enterprise v. City of Santa Fe, No. D-0101-CV-2003-468 (attached as Ex. A).

The state court lawsuit was thoroughly litigated in the trial court over the subsequent fifteen months.  The trial court heard the City’s motions for summary judgment and plaintiffs’ motion for a preliminary injunction in December 2003, after which the court dismissed many of plaintiffs’ claims, ordered a trial on the remaining issues, and enjoined enforcement of the Ordinance pending trial.  After months of pre-trial motions, discovery, and depositions, the trial was held from April 12-16, 2004. 

On June 24, 2004, the state court issued its final decision, accompanied by 45 pages of findings of fact and conclusions of law.  The court ruled for the City on all claims, upheld the Ordinance as valid, dissolved its injunction, and ordered that the Ordinance take effect immediately.  The state court plaintiffs are now appealing that decision to the New Mexico Court of Appeals.

In December 2003, the Chamber and NMFE moved forward with the second prong of their legal strategy, by orchestrating the filing of this federal court lawsuit by Chamber member, Coca Cola.  At that time, the January 1, 2004 effective date of the Ordinance was approaching, and the state court had not ruled on the state plaintiffs’ motion for a preliminary injunction.  As stated publicly by NMFE at the time, it initiated the federal lawsuit in order to permit the business community to seek an injunction in federal court in the event that the state court denied their request.  Upon filing the federal court action on December 18, 2003, NMFE’s Executive Director explained to the media that “his group intend[ed] to pursue the state case, but believe[d] it has a better chance of winning an injunction in federal court.”  Tom Sharpe, Federal Suit Filed to Halt Wage Law, Santa Fe New Mexican, Dec. 18, 2003, at A-1.

The federal court complaint is virtually identical to that in the state court action.  The state constitutional analogs of three of Plaintiff’s four federal claims― equal protection, vagueness, and substantive due process ― were litigated in the state case.  The only new federal claim is Count 5 ― Plaintiff’s vague (and frivolous) Privileges or Immunities Clause claim.  Indeed, in many instances the language used in the federal complaint is virtually identical to the language used in the state complaint.

As the City will demonstrate below, Coca Cola’s federal claims are not even colorable, but apparently are intended to serve as a federal jurisdictional mechanism by which to relitigate the very same state law claim ― whether Santa Fe has authority under New Mexico’s constitutional home rule provision to enact a minimum wage law ― that had been the focus of the state lawsuit.  This state claim, which raises a question of first impression under New Mexico law, has been the subject of more than a year of litigation in the state court.

As it turned out, seeking a federal court injunction in December 2003 proved unnecessary as the state court issued a preliminary injunction barring enforcement of the Ordinance pending trial.  With the state court injunction in place, Coca Cola, NMFE, and the Chamber took no further action on the federal lawsuit, and refrained from serving the summons and complaint until some four months later, on April 14, 2004.  Their aim was apparently intended to keep this case in reserve for later activation in the event that the state court dissolved its injunction after the April trial.

            Now that the state court has decided the case and lifted the injunction, Plaintiff Coca Cola evidently seeks to activate this lawsuit and seek a preliminary injunction from this court barring enforcement of the Ordinance.  See John T. Huddy, Coke Co. to Take “Wage” to Court, Albuquerque Journal, June 29, 2004, at 1.

 

LEGAL STANDARD

            A motion to dismiss under Fed. R. Civ. P. 12(b)(6) should be granted where it appears beyond doubt that the plaintiff can prove no set of facts in support of his or her claim which would entitle him or her to relief.  Sutton v. Utah State Sch. for Deaf and Blind, 173 F.3d 1226, 1236 (10th Cir. 1999).  “The court’s function on a Rule 12(b)(6) motion is not to weigh potential evidence that the parties might present at trial, but to assess whether the plaintiff’s complaint alone is legally sufficient to state a claim for which relief may be granted.”  Id. (quoting Miller v. Glanz, 948 F.2d 1562, 1565 (10th Cir.1991)).

 

ARGUMENT

I.                PLAINTIFF’S FEDERAL CLAIMS ARE WITHOUT LEGAL BASIS AND WARRANT DISMISSAL

The four substantive federal claims[6] pleaded in Plaintiff’s Complaint ― that the Ordinance and its classifications violate equal protection, vagueness, substantive due process, and the Privileges or Immunities Clause, all under the Fourteenth Amendment of the U.S. Constitution ― are without legal basis and warrant dismissal.  Plaintiffs’ objections to the Ordinance, were they well-founded, would equally invalidate numerous state and federal labor and employment laws, including the New Mexico Minimum Wage Act (“MWA”), N.M. Stat. Ann. § 50-4-22 et seq., and the federal Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201 et seq., since they incorporate many of the same features that Plaintiff challenges in the Ordinance.  But federal law on all of these points has been clear for more than fifty years.   Rejecting legal challenges to the legislative reforms of the New Deal, the U.S. Supreme Court long ago upheld economic regulatory legislation such as minimum wage laws, and rejected the notion that they should be subject to exacting review under the Fourteenth Amendment.

A.              The Ordinance Does Not Deny Plaintiff Equal Protection of the Law

 

Plaintiff’s first substantive claim is that the Living Wage Ordinance violates the Equal Protection Clause of the Fourteenth Amendment “by creating arbitrary and capricious classes for those individuals desiring to conduct business in the City of Santa Fe.”  See Compl. ¶ 54; see also id. ¶¶ 58, 60, 64, 66, 68, 70, 71, 73, 75 (identifying nine classifications that Plaintiff claims “bear[] no rational relationship to the stated purpose of the Ordinance”).  This assertion lacks any legal support.   The classifications challenged are of the sort routinely found in regulatory legislation.  As explained below, various rational bases for each of them are readily apparent.

As a threshold matter, it is critical to note that classifications contained in economic regulatory legislation such as the Ordinance are subject only to “rational basis” review ― the most deferential form of equal protection scrutiny.  As the Supreme Court has instructed,

In areas of social and economic policy, a statutory classification that neither proceeds along suspect lines nor infringes fundamental constitutional rights must be upheld against equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification.  Where there are “plausible reasons” for [the legislative] action, our inquiry is at an end.

 

F.C.C. v. Beach Communications, Inc., 508 U.S. 307, 313-14 (1993) (citations omitted).  See Grigsby v. Barnhart, 294 F.3d 1215, 1220 (10th Cir. 2002); Allright Colorado, Inc. v. City and County of Denver, 937 F.2d 1502, 1512 (10th Cir. 1991).

            Described as “a paradigm of judicial restraint,” Beach, 508 U.S. at 313, this minimal level of scrutiny is grounded in courts’ institutional deference to legislative choices:

The Constitution presumes that, absent some reason to infer antipathy, even improvident decisions will eventually be rectified by the democratic process and that judicial intervention is generally unwarranted no matter how unwisely we may think a political branch has acted.

 

Id. at 313-14 (quoting Vance v. Bradley, 440 U.S. 93, 97 (1979)). 

            As a result, the court need only conclude that there could be a “reasonably conceivable state of facts that could provide a rational basis for the classification . . . .  [A] legislative choice is not subject to courtroom fact-finding and may be based on rational speculation unsupported by evidence or empirical data.”  Cordoba v. Massanari, 256 F.3d 1044, 1049 (10th Cir. 2001) (quoting Beach, 508 U.S. at 313, 315) (internal quotation marks omitted).

Especially in fashioning legislative classifications, lawmakers enjoy extraordinarily wide latitude.  As the Supreme Court explained nearly half a century ago,

Evils in the same field may be of different dimensions and proportions, requiring different remedies.  Or so the legislature may think.  Or the reform may take one step at a time, addressing itself to the phase of the problem which seems most acute to the legislative mind.  The legislature may select one phase of one field and apply a remedy there, neglecting the others. 

 

Williamson v. Lee Optical, 348 U.S. 483, 489 (1955) (internal citations omitted).  Indeed, the Court has gone even further, explaining that,

Such scope-of-coverage provisions are unavoidable components of most economic or social legislation.  . . .  This necessity renders the precise coordinates of the resulting legislative judgment virtually unreviewable, since the legislature must be allowed leeway to approach a perceived problem incrementally.

 

Beach, 508 U.S. at 316 (emphasis added).  “By necessity, the lines drawn between the categories may be arbitrary, but that does not make the categorization impermissible.”  Daniels v. Apfel, 154 F.3d 1129, 1132 (10th Cir. 1998) (citing Califano v. Aznavorian, 439 U.S. 170, 174 (1978)) (emphasis added).

Plaintiff alleges that at least nine of the Ordinance’s classifications, which define which businesses are and are not covered by the living wage, are unconstitutionally arbitrary.  But a moment’s consideration makes clear that for each of them a “reasonably conceivable state of facts that could provide a rational basis for the classification” is evident.  Cordoba, 256 F.3d at 1049.

For example, Plaintiff alleges that there is no conceivable rational basis for the Ordinance’s provision (§ 28-1.5(A)(4)) limiting coverage to businesses required “to have a business license or business registration from the city of Santa Fe.”  Compl. ¶¶ 56-58.  Plaintiff makes no effort to explain why such a classification lacks any rational basis, and straightforward explanations for the classification are readily apparent.  For example, the City Council might well have concluded that limiting coverage to businesses that are already subject to licensing by the City would be simplest administratively, rather than attempting to include businesses “licensed in other cities, but having no offices in Santa Fe.”  Compl.  ¶ 57.  See Edwards v. Valdez, 789 F.2d 1477, 1483 (10th Cir. 1986) (recognizing that ease of administration is a legitimate governmental interest).

Plaintiff goes on to complain that, by limiting coverage to employers with business licenses, the Ordinance effectively exempts various other employers, including “state and federal employers.”  Compl.  ¶ 57.  Again, administrative ease readily justifies the Ordinance’s approach to coverage.  Additionally, the Council might have questioned whether it had the legal authority to regulate the wages paid by state and federal agencies.  Or, it could also have concluded that poverty wages posed less of a problem among state and federal employers, since most government jobs pay substantially more than minimum wage.

Similarly, rational bases for the Ordinance’s limiting of coverage to hours worked within the City of Santa Fe, Compl. ¶ 65, might include administrative ease, or perhaps concern by the City Council that their regulatory powers were limited to work performed within the City.

Surprisingly, Plaintiff also challenges as unconstitutionally irrational the Ordinance’s limiting of its coverage to firms that have 25 or more employees.  Compl. ¶¶ 59, 60.  However, such firm-size coverage thresholds are found in myriad labor and employment laws at the federal, state, and local levels.  See, e.g., Age Discrimination in Employment Act, 29 U.S.C. § 630(b) (2000) (20 or more employees); Civil Rights Act of 1964, Title VII, 42 U.S.C. § 2000e(b) (2002) (15 or more employees); N.M. Hum. Rights Act, N.M. Stat. Ann. § 28-1-2(B) (Michie 1978) (4 or more employees); N.M. Workers Compensation Act, § 52-1-2 (Michie 1978) (3 or more employees).  Obvious, rational bases for excluding smaller businesses from regulatory requirements include, for example, a concern that smaller businesses might be less able to bear the cost of complying, or that government enforcement resources should be focused on businesses employing larger numbers of workers.

In 1937, the Supreme Court laid to rest the notion that use of such coverage thresholds violated equal protection:

It is argued here, and it was ruled by the court below, that there can be no reason for a distinction . . . between those who have only seven employees and those who have eight.  Yet, this is the type of distinction which the law is often called upon to make.  It is only a difference in numbers which marks the moment when day ends and night begins, when the disabilities of infancy terminate and the status of legal competency is assumed.  It separates large incomes which are taxed from the smaller ones which are exempt, as it marks here the difference between the proprietors of larger businesses who are taxed and the proprietors of smaller businesses who are not.

 

Carmichael v. Southern Coal & Coke Co., 301 U.S. 495, 510-11 (1937).  Stressing that “The[] restraints on judicial review have added force where the legislature must necessarily engage in a process of line-drawing,” Beach, 508 U.S. at 315, the Supreme Court has time and again warned that

Defining the class of persons subject to a regulatory requirement ― much like classifying governmental beneficiaries ― inevitably requires that some persons who have an almost equally strong claim to favored treatment be placed on different sides of the line, and the fact [that] the line might have been drawn differently at some points is a matter for legislative, rather than judicial, consideration.

 

Id. at 315-16 (internal quotations & citations omitted).  Accordingly, attempts to challenge the constitutionality of coverage thresholds in minimum wage laws have always been dismissed out of hand by federal courts.  See, e.g., RUI One Corp. v. City of Berkeley, 2004 WL 1336657, *13-15 (9th Cir. June 16, 2004) (rejecting equal protection challenge to living wage ordinance applying only to employers in certain geographic areas, with more than six employees, grossing more than $350,000 annually, but not applying to “other similar business elsewhere in the City”).

Plaintiff also challenges as arbitrary the Ordinance’s coverage of businesses that receive grants, subsidies, loans or industrial revenue bonds from the City of $25,000 or more, or that perform contracts for the City valued at $30,000 or more.  Compl. ¶¶ 67-70.  Such coverage provisions are found in virtually every living wage law and reflect a judgment that, where a business receives a large taxpayer-funded benefit, it is appropriate to ask them to pay a living wage in return.  As with firm-size thresholds, legislatures enjoy broad discretion in setting the level of such thresholds, which are not subject to further review by the courts.  See Beach, 508 U.S. at 316 (finding that even when two classes have an almost equally strong claim to favored treatment “the fact [that] the line might have been drawn differently at some points is a matter for legislative, rather than judicial, consideration”).

Plaintiff next challenges Ordinance § 28-1.7, which exempts from coverage businesses that “recogniz[e] an exclusive representative for employees and execut[e] a bona fide collective bargaining agreement by and between an employer and its employees.”  Compl. ¶¶ 61-64.  Like numerical coverage thresholds, such exemptions from regulatory requirements for workers covered by collective bargaining agreements are commonplace in federal, state and local labor and employment laws.  See, e.g., FLSA, 29 U.S.C. § 203(m) (2000) (providing that employers need not include the cost of board, lodging and other facilities as an element of wages “to the extent it is excluded therefrom under the terms of a bona fide collective-bargaining agreement applicable to the particular employee”); MWA, N.M. Stat. Ann § 50-4-2(C) (Michie 1978) (providing that certain employees may be paid once a month, but not “those employees whose salaries are subject to provisions of collective bargaining agreements”); Brief for Employers Group et al. as Amici Curiae, Livadas v. Bradshaw, 512 U.S. 107, at Addendum B (1994) (available at 1992 U.S. Briefs 1920 (Lexis)) (cataloging 32 state code provisions from 19 states containing collective bargaining opt-out provisions).

Courts have routinely dismissed equal protection challenges to such exemptions, explaining that rational bases for them are readily apparent.  For example, a “[l]egislature could rationally have believed that workers covered by collective bargaining agreements . . . have greater power to ensure [adequate] working conditions than workers with individual employment agreements.”  Viceroy Gold v. Aubrey, 75 F.3d 482, 491 (9th Cir. 1996) (upholding California statute exempting employees covered by collective bargaining agreements from maximum hour requirements).  Indeed, as the Ninth Circuit explained recently,

As the Supreme Court has observed in a case determining whether a state labor policy was preempted by federal law, “a number of state and federal laws . . . draw distinctions between union and nonunion represented employees,” Livadas v. Bradshaw, 512 U.S. 107, 131 (1994) (citing 29 U.S.C. § 203(o); D.C. Code Ann. §  36-103 (1993)), in which the content of collective bargaining agreements can affect whether and how a statute applies.  The Court referred to these as “familiar and narrowly drawn opt-out provisions.”  Id. at 132; see also Cal. Lab. Code § 554 (mandating one rest day per seven-day period “unless the collective bargaining agreement expressly provides otherwise”).

 

RUI One Corp., 2004 WL 1336657, at *16 (upholding against due process challenge provision of Berkeley’s living wage ordinance allowing businesses with “bona fide collective bargaining agreements to opt out of the ordinance”).[7]

The Ordinance’s other exemptions challenged by Plaintiff are similarly routine and supported by obvious rational bases.  Plaintiff challenges the exemption from the Ordinance’s coverage of city contractors of any non-profit organizations that contract with Santa Fe, Ordinance § 28-1.5(A)(2), and the complete exemption of non-profits primarily funded by Medicaid waivers, id. § 28-1.5(C).  Compl. ¶¶ 71,74.  Clearly, the City Council rationally could have concluded that such non-profits enjoy less flexibility to raise new revenues to cover the costs of paying a living wage and so decided to exempt them.

Finally, Plaintiff challenges the Ordinance’s exclusion of (a) interns working for academic credit in connection with a course of study at an accredited school, (b) workers who are in an apprenticeship program in a 501(c)(3) (non-profit) organization, and (c) persons working in connection with a court-ordered community service program.  Ordinance § 28-1.5(A)(4); Compl. ¶¶ 72-73.  All of these exclusions involve special categories of workers that derive non-monetary benefits from their employment:  the student intern receives academic credit, the apprentice receives experience from the non-profit; and the community-service worker receives leniency from the court.  The City Council could rationally have concluded that, in light of these additional benefits, and in order to create an incentive for employers to continue participating in such programs, it made sense to exempt such workers from the living wage.

Again, all of the challenged classifications are of the sort commonly found in labor and employment regulations across the country.  Plaintiff’s complaint tacitly and improperly asks this Court to “judge the wisdom, fairness, or logic of [these] legislative choices,” Beach, 305 U.S. at 313, in contravention of long-settled Supreme Court teaching.  See Heller v. Doe, 397 U.S. 312, 318 (1993) (“Nor does [the Equal Protection Clause] authorize ‘the judiciary [to] sit as a superlegislature to judge the wisdom or desirability of legislative policy determinations made in areas that neither affect fundamental rights nor proceed along suspect lines.’” (quoting New Orleans v. Dukes, 427 U.S. 297, 303 (1976)).  The choice to distinguish “between the proprietors of large businesses which are [covered] and the proprietors of smaller businesses who are not” is necessarily left to the City Council.  Carmichael, 301 U.S. at 511.  As conceivable rational bases for all of the challenged classifications are apparent to even a casual observer, Plaintiff’s equal protection challenge must be dismissed.

 

B.              The Ordinance Does Not Violate Substantive Due Process

 

In the Complaint’s second substantive count, Count 3, Plaintiff alleges that the Ordinance violates the substantive due process component of the Fourteenth Amendment because it is not the “most rational means” by which to satisfy the Ordinance’s stated objectives.  Compl. ¶ 80 (emphasis added).  Plaintiff goes on to assert that the Ordinance will result in “higher unemployment, higher prices, decreases in benefits offered to employees, an increase in the demand for highly skilled and highly educated workers, and a migration of businesses from the City of Santa Fe.”  Id.[8]

In arguing that the Ordinance must employ the most rational means available for achieving its aims, Plaintiff fundamentally misunderstands substantive due process.  Explaining the exceedingly narrow contours of such review, the Supreme Court has repeatedly emphasized that legislative bodies “have the broad scope to experiment with economic problems, and this Court does not sit to subject [state and local governments] to an intolerable supervision hostile to the basic principles of our government and wholly beyond the protection which the . . . [Due Process Clause] was intended to secure.”  Ferguson v. Skrupa, 372 U.S. 726, 729-30 (1963).  See Lincoln Federal Labor Union v. Northwestern Iron and Metal Co., 335 U.S. 525, 536-37 (1949) (“[T]he due process clause is no longer to be so broadly construed that the Congress and state legislatures are put in a strait jacket when they attempt to suppress business and industrial conditions which they regard as offensive to the public welfare.”).

As the Tenth Circuit has explained, so long as a statute does not “trammel[] fundamental personal rights, we are to presume that . . . legislatures have acted within their constitutional power and are to require only that the law bears a reasonable relation to the state’s legitimate purpose . . . .”  Oklahoma Educ. Ass’n v. Alcoholic Beverage Laws Enforcement Com’n, 889 F.2d 929, 935 (10th Cir. 1989) (internal quotation marks omitted).  For economic legislation like the Ordinance, rational basis review in the substantive due process context mirrors that of equal protection:  “It is enough that there is an evil at hand for correction, and that it might be thought that the particular legislative measure was a rational way to correct it.”  Murphy v. Matheson, 742 F.2d 564, 576 (10th Cir. 1984) (quoting Williamson, 348 U.S. at 488) (emphasis added).  And as the Tenth Circuit was warned, “When local economic or social regulation is challenged as violating substantive due process, courts consistently defer to legislative determinations as to the desirability of particular statutory schemes.”  Oklahoma Educ. Ass’n, 889 F.2d at 935.

The notion that minimum wage legislation violates due process was categorically rejected by the Supreme Court in 1937 in West Coast Hotel Co. v. Parrish, 300 U.S. 578, 398-400 (1937).  In West Coast Hotel, the Court stressed:

In dealing with the relation of employer and employed, the Legislature has necessarily a wide field of discretion in order that there may be suitable protection of health and safety, and that peace and good order may be promoted through regulations designed to insure wholesome conditions of work and freedom from oppression.

 

Id. at 393.  Explaining the straightforward and compelling public policy reasons for minimum wage legislation, the Court reasoned that such legislation guards against the exploitation of workers who are in an “unequal position with respect to bargaining power” and “relatively defenseless.”  Id. at 399.  The Court continued that “the denial of a living wage is not only detrimental to [workers’] health and well being, but casts a direct burden for their support upon the community.  What these workers lose in wages the taxpayers are called upon to pay.”  Id.

Here, the higher minimum wage provided for under the Ordinance is clearly a permissible means by which the City Council and the Santa Fe community may choose to help local workers “meet the basic needs of living in Santa Fe,” Ordinance, § 28-1.4, improve their lives, and reduce the effects of the erosion of the federal minimum wage on the City itself.  Id. at § 28-1.2.

 As the Tenth Circuit has instructed, “[T]he Due Process Clause does not empower the judiciary ‘to sit as a ‘superlegislature to weigh the wisdom of legislation.’” Murphy, 742 F.2d at 574 (quoting Ferguson, 372 U.S. at 731).  The Supreme Court long ago explained that, “[t]he day is gone when this Courts uses the Due Process Clause of the Fourteenth Amendment to strike down state laws, regulatory of business and industrial conditions, because they may be unwise, improvident, or out of harmony with a particular school of thought.”  Williamson, 348 U.S. at 488.  Although Plaintiff may believe that the Ordinance is not the best approach for addressing the plight of Santa Fe’s low-wage workers, Compl. ¶ 80, that decision is properly reserved for Santa Fe’s legislators, in the context of political and public debate, not the courts. 

Because the Ordinance is rationally related to a legitimate governmental purpose, Plaintiff’s due process claim must be dismissed.

 

C.              The Ordinance Is Not Unconstitutionally Vague

 

The Complaint’s next substantive claim, Count 4, charges that certain provisions of the Ordinance are “so vague and ambiguous that it is unconstitutional.”  Compl. ¶ 86.  First, Plaintiff charges that Ordinance§ 28-1.5(B), which allows “the value of health benefits and childcare [to] be considered as an element of wages” and credited towards satisfaction of the $8.50 minimum wage, leaves a business owner “to guess as to how to convert the value of health benefits and childcare into an hourly rate for purposes of including them as an element of wages.”  Compl. ¶ 88.  Second, Plaintiff challenges as unconstitutionally vague another provision of Ordinance § 28-1.5(B) ― which provides that tips and commissions shall be counted as wages and credited towards payment of the minimum wage for “workers who customarily receive more than $100 per month in tips or commissions,” (emphasis added) ― because “it fails to provide a definition, or any guidance, for the term ‘customarily.’”  Compl. ¶ 91.

As an initial matter, Coca Cola has not alleged — and it seems unlikely that it will be able to show — that it is actually affected by these provisions, and that therefore it has standing to challenge them.  Plaintiff would be affected by them only if it currently provides health or childcare benefits to any of its workers who earn less than the Ordinance’s current $8.50 minimum wage ― or if it currently employs tipped workers who earn less than $8.50 an hour.  Since few employers provide health or child care benefits to low-wage workers, and since the Coca Cola Bottling Co. is unlikely to employ tipped workers, it probably is not affected by these provisions ― and therefore lacks standing to challenge them.  If the Court does not grant this motion, the City will seek dismissal of the vagueness claim on standing grounds once discovery has confirmed whether Plaintiff employs workers that are affected by these provisions.

But whether or not Plaintiff actually has standing to raise the vagueness claim, the count clearly warrants dismissal as it fails to state a claim.  “[T]he vagueness doctrine bars enforcement of ‘a statute which either forbids or requires the doing of an act in terms so vague that men of common intelligence must necessarily guess at its meaning and differ as to its application.’”  U.S. v. Lanier, 520 U.S. 259, 266 (1997) (quoting Connally v. General Constr. Co., 269 U.S. 385, 391 (1926)).  Even when sensitive First Amendment rights or criminal sanctions are involved, courts will not strike down a law on a facial challenge (such as this action) simply because it presents an “imprecise but comprehensible normative standard.”  Coates v. Cincinnati, 402 U.S. 611, 614 (1971).  Only when “no standard of conduct is specified at all” in the legislation, id., will it be invalidated as unconstitutionally vague.

The Supreme Court has further explained that in the case of economic regulation, such as the Ordinance, vagueness review is even more deferential:

The degree of vagueness that the Constitution tolerates ― as well as the relative importance of fair notice and fair enforcement ― depends in part on the nature of the enactment.  Thus, economic regulation is subject to a less strict vagueness test because its subject matter is often more narrow, and because businesses, which face economic demands to plan behavior carefully, can be expected to consult relevant legislation in advance of action.  Indeed, the regulated enterprise may have the ability to clarify the meaning of the regulation by its own inquiry, or by resort to an administrative process.

 

Village of Hoffman Estates v. Flipside, Hofmann Estates, Inc., 455 U.S. 489, 498 (1982).

The challenged provisions are not only understandable by persons “of common intelligence,” but are virtually identical to provisions contained in both federal and New Mexico statutes that have been understood and administered without incident for decades.

There is nothing ambiguous about Ordinance § 28-1.5(B)’s instruction that “In computing the wage paid for purposes of determining compliance with the minimum wage, the value of health benefits and childcare shall be considered as an element of wages.”  The provision means what it says:  In assessing whether it may continue paying any of its employees a cash wage of less than the Ordinance’s $8.50 minimum wage, Plaintiff should calculate the per hour amount of any expenditure it makes to provide health or child care benefits to the employee and then determine whether that amount, combined with the hourly cash wage, totals at least $8.50.[9]

Similar provisions authorizing that certain benefits provided by employers may be counted as wages for purposes of complying with wage regulations can be found throughout federal and state law.  See, e.g., Davis-Bacon Act, 40 U.S.C.A. § 3141 et seq. (formerly 40 U.S.C. § 276(a)) (requiring certain federal contractors to pay their employees the “prevailing wage” and providing that in addition to the basic hourly amount of pay, the term “wages” may include payments for “medical or hospital care,” “pensions,” “insurance,” and “other bona fide fringe benefits”); N.M. Public Works Minimum Wage Act, N.M. Stat. Ann. § 13-4-12(A)(2)(b) (Michie 1978) (requiring the same for certain state contractors); MWA, N.M. Stat. Ann. § 50-4-22(A) (providing exception to minimum wage such that “an employer furnishing food, utilities, supplies or housing to an employee who is engaged in agriculture may deduct the reasonable value of such furnished items from any wages due to the employee” (emphasis added)); N.M. Workers Compensation Act, N.M. Stat. Ann. § 52-1-20 (Michie 1978) (providing that the term “‘average weekly wage’ shall include the reasonable value of board, rent, housing or lodging received from the employer, which shall be fixed and determined from the facts in each particular case”) (emphasis added); Rate of contribution or cost for fringe benefits, 29 C.F.R. § 5.25 (2003) (explaining that the “rate of contribution or cost is ordinarily an hourly rate, and will be reflected in the wage determination as such”). 

Like the Ordinance, these state and federal statutes provide no detailed explanation about procedures for converting into wages the value of benefits provided.  Yet their constitutionality has not been questioned and employers and enforcement officials have had little difficulty understanding and applying them.

Similarly, there is nothing vague about Ordinance § 28-1.5(B), which provides that “For workers who customarily receive more than $100 per month in tips or commissions, any tips or commissions received and retained by a worker shall be counted as wages and credited towards satisfaction of the minimum wage.”  The Complaint charges that because the Ordinance “does not provide a definition, or any guidance, for the term ‘customarily,’” it forces employers to engage in an “exercise in guesswork and speculation” to determine how to comply.  Compl. ¶ 91.[10]

But employers of tipped workers have for decades understood and complied with virtual identical provisions contained in the New Mexico Minimum Wage Act and the federal Fair Labor Standards Act.  See FLSA, 29 U.S.C. § 203(t) (2002) (providing that a “[t]ipped employee means any employee engaged in an occupation in which he customarily and regularly receives more than $30 a month in tips”) (emphasis added); MWA, N.M. Stat. Ann. § 50-4-22(B) (Michie 1978) (stating that all employees who “customarily and regularly receive more than thirty dollars ($30.00) a month in tips shall be paid a minimum hourly wage of two dollars twelve and one-half cents ($2.125).  The employer may consider tips as wages, but such a wage credit shall not exceed fifty percent of the minimum wage.”) (emphasis added).   Accordingly, Plaintiff’s claim that the Ordinance’s health, child care, and tip credit provisions are unconstitutionally vague is without any legal or factual basis and should be dismissed.

 

D.              The Ordinance Does Not Violate the Privileges or Immunities Clause of the Fourteenth Amendment

 

In the Complaint’s final and perhaps most novel federal claim, Count 5, Plaintiff alleges that the Ordinance violates the Privilege or Immunities Clause of the Fourteenth Amendment.  But long ago in the Slaughter-House Cases, 83 U.S. (16 Wall.) 36 (1872), the Supreme Court rejected the idea that the Privilege or Immunities Clause protects businesses against economic regulation, holding instead that the clause extends protection only in very limited areas.  With the exception of a single, short-lived decision from the Lochner era ― see Colgate v. Harvey, 296 U.S. 404 (1935), overruled by Madden v. Kentucky, 309 U.S. 83 (1940) ― the only right that a majority of the Supreme Court has ever found to be protected by the Privileges or Immunities Clause is the right to inter-state travel.  See Saenz v. Roe, 526 U.S. 489, 503-04 (1999) (restricting state policies that burden the right to travel by discriminating against out-of-state residents).  As has been recognized time and again since Slaughter-House, the Court’s narrow construction of the Privileges or Immunities Clause “essentially den[ies] the provision any significant content.”  1 Laurence H. Tribe, American Constitutional Law § 7-5, at 1316 (3d ed. 2000).

As the Privilege or Immunities Clause has never been found to limit minimum wage regulation in any way, this claim ― like Plaintiff’s other federal claims ― is frivolous and must be dismissed.

 

II.              THE COURT SHOULD DECLINE TO EXERCISE SUPPLEMENTAL JURISDICTION OVER THE PLAINTIFF’S PENDENT STATE CLAIM

 

As demonstrated above, Plaintiff’s federal claims are without any colorable basis.  Plaintiff seems to have pled them to justify federal jurisdiction over a lawsuit to which the only real claim ― the state law question of whether the Ordinance falls within the City’s home rule powers under the New Mexico Constitution ― could be appended.  Because the federal claims warrant dismissal and ― even if they didn’t ― because the pendent state law claim poses a “complex issue of State law,” exercise of supplemental jurisdiction is inappropriate.  The state law claim ― and with it, the entire lawsuit ― should be dismissed pursuant to 28 U.S.C. § 1367(c).

Under the supplemental jurisdiction statute, a federal court possessing original jurisdiction over a federal claim may exercise jurisdiction over state claims that form part of the same “case or controversy” as the underlying federal matter.  28 U.S.C. § 1367(a).  However, under the statute, the court may decline to exercise such supplemental jurisdiction over a pendent state claim where:

(1) the claim raises a novel or complex issue of State law,

(2) the claim substantially predominates over the claim or claims over which the district court has original jurisdiction,

(3) the district court has dismissed all claims over which it has original jurisdiction, or

(4) in exceptional circumstances, there are other compelling reasons for declining jurisdiction.

 

28 U.S.C. § 1367(c). 

In deciding whether to retain jurisdiction over a supplemental state claim, a judge must exercise discretion “in those cases in which, given the nature and extent of pretrial proceedings, judicial economy, convenience, and fairness would be served by retaining jurisdiction.”  Anglemeyer v. Hamilton County Hosp., 58 F.3d 533, 541 (10th Cir. 1995) (quoting Thatcher Enter. V. Cache County Corp., 902 F.3d 1472, 1478 (10th Cir. 1990)).  As the Supreme Court has explained, “[pendent jurisdiction’s] justification lies in considerations of judicial economy, convenience, and fairness to litigants; if these are not present a federal court should hesitate to exercise jurisdiction over state law claims . . . .”  United Mine Workers v. Gibbs, 383 U.S. 715, 726 (1966).  This need for caution is grounded both in a respect for state legal development and a concern for justice between the parties:  “Needless decisions of state law should be avoided both as a matter of comity and to promote justice between the parties, by procuring for them a surer-footed reading of applicable law.”  Id.

Here, the state claim should be dismissed under both 28 U.S.C. § 1367(c)(3) — because the Court will likely dismiss all of the Plaintiff’s federal claims — and 28 U.S.C. § 1367(c)(1) — because it raises a complex issue of state law.  See O’Connor v. Nevada, 27 F.3d 357, 362-63 (9th Cir. 1994) (“[D]istrict courts may decline to exercise supplemental jurisdiction over a claim if any one of the four circumstances listed in the statute exist.”) (emphasis added) (internal quotation marks omitted).

With regard to the former, the Tenth Circuit teaches that “the most common response to a pretrial disposition of federal claims has been to dismiss the state law claim or claims without prejudice — that is the seminal teaching of United Mine Workers v. Gibbs, [383 U.S. 715, 726 (1966)].”  Roe v. Cheyenne Mountain Conference Resort, Inc., 124 F.3d 1221, 1237 (10th Cir. 1997).  See also United Mine Workers, 383 U.S. at 726 (“Certainly, if the federal claims are dismissed before trial, even though not insubstantial in a jurisdictional sense, the state claims should be dismissed as well.”).  This is particularly true where, as here, the parties have not invested the time and expense associated with full discovery.  See Tonkovich v. Kansas Bd. of Regents, Univ. of Kansas, 254 F.3d 941, 946 (10th Cir. 2001) (“[G]iven the relative lack of pretrial proceedings — including a total absence of discovery — considerations of judicial economy, convenience, and fairness do not favor retaining jurisdiction.”) (internal quotation marks omitted).

Moreover, even if the federal claims are not dismissed, the state claim should be dismissed under 28 U.S.C. § 1367(c)(1) because it raises a complex issue of state law that is presently proceeding through the New Mexico courts.  See Cheyenne Mountain Conference Resort, 124 F.3d at 1237 (dismissing a claim raising a “complex issue of state law that is undecided by the Colorado courts”).  “The Supreme Court has counseled that the proper function of a federal court is to ascertain what state law is, not what it ought to be.”  Women Prisoners of D.C. Dep’t of Corrections v. D.C., 93 F.3d 910, 922 (D.C. Cir. 1996) (quoting Klaxon v. Stentor Electric Mfg. Co., 313 U.S. 487, 497 (1941)).  Allowing the appeal in the state case to work its way through the New Mexico court system is the most appropriate course of action, as it will conserve federal judicial resources, without inconveniencing Plaintiff or burdening its rights, and it will allow New Mexico’s judiciary to resolve this complex issue.

Indeed, if this Court were to retain jurisdiction over the state claim, it would, in any event, be obliged to follow the New Mexico courts’ decision.  Considerations of judicial economy therefore counsel in favor of dismissing the pending state claim and allowing Plaintiff to receive resolution of the state law issue through the appeal now pending in state court.

 

III.            Thibodaux Abstention Requires the Court to Stay This Action Pending Resolution of the State Law Claim By the New Mexico Appellate Courts

In the event that this Court does not dismiss Plaintiff’s federal and state claims ― and, as explained above, dismissal is clearly warranted ― the Court should, under the abstention principle outlined in Thibodaux v. Louisiana Power & Light Co., 360 U.S. 25 (1959), stay further proceedings pending resolution of the state law question in the ongoing litigation in the New Mexico courts.  Thibodaux abstention was developed for precisely the circumstance presented here:  where a federal complaint raises an important and complex state law question concerning “the apportionment of government powers between City and state.”  Id. at 28.

As it has worked to fashion a set of abstention principles to guide the federal courts, the Supreme Court has long recognized “the wisdom of staying actions in the federal courts pending determination by a state court of decisive issues of state law.”  Id. at 27.  The Supreme Court developed Thibodaux abstention to permit federal courts to refrain from exercising jurisdiction in cases “present[ing] difficult questions of state law bearing on policy problems of substantial public import whose importance transcends the result in the case then at bar.”  Colorado River Water Conservation Dist. v. United States, 424 U.S. 800, 814 (1976) (describing Thibodaux abstention).

This teaching reflects respect for the principles of “our federalism,” Thibodaux, 360 U.S. at 28, by permitting a federal co