pizza delivery driver delivering pizza to customer, both are wearing masks

Domino’s Delivery Lawsuit Filed Against M3K, LLC

Case Update: Settlement Reached

Forester Haynie successfully resolved this case in favor of the delivery drivers.

A lawsuit has been filed against M3K, LLC and owner, Dominic Pitarro on behalf of Christopher Reed, a former Domino’s delivery driver Christopher Reed and other similarly situated delivery drivers. M3K, LLC currently operates four Domino’s Pizza franchise locations in Tennessee.

The lawsuit alleges that M3K, LLC failed to properly reimburse delivery drivers for the business expenses they incurred while using their personal vehicles to make deliveries. Delivery drivers are responsible for covering significant vehicle-related costs, including gasoline, maintenance, repairs, insurance, and depriciation

According to the complaint, the reimbursement rates paid to the drivers were insufficient to cover these expenses. As a result, drivers’ net wages allegedly fell below the federal wage in violation of the Fair Labor Standards Act (FLSA).

The lawsuit further alleges that the reimbursement method used by M3K, LLC did not accurately reflect the true cost of operating a personal vehicle for delivery work. During the relevant time period, rising fuel prices and increased vehicle expenses placed additional financial burdens on delivery drivers. In response to these increased costs, the Internal Revenue Service (IRS) raised its standard mileage rate to 62.5 cents per mile for the second half of 2022.

The case is titled Christopher Reed v. M3K, LLC and Dominic Pitarro and is currently pending in the United States District Court for the Eastern District of Tennessee.

About Forester Haynie

Forester Haynie is committed to protecting workers’ rights and holding employers accountable for wage and hour violations. The firm’s attorneys represent employees in cases involving minimum wage violations, unpaid wages, and other Fair Labor Standards Act claims.

Many delivery drivers are unaware that inadequate vehicle expense reimbursements can reduce their effective hourly pay below the federal minimum wage. Forester Haynie works to recover unpaid wages and seek fair compensation for workers affected by these practices.

The firm has recovered more than $10 million on behalf of delivery drivers nationwide. Because wage and hour litigation can take time, Forester Haynie remains committed to pursuing justice for its clients throughout the legal process. Clients pay no upfront fees or litigation costs. Forester Haynie only gets paid if it successfully recovers compensation on their behalf.

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