Domino’s Driver Files Suit Alleging Improper Reimbursement of Delivery Expenses

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A class and collective action filed against Tiger Eye Pizza, LLC and one individual owner alleges the parties violated federal and state labor laws by failing to properly reimburse their delivery drivers for automobile expenses.

The plaintiff, who receives a tipped hourly wage of $4.25 as a driver at an Arkansas Domino’s Pizza franchise owned by the defendants, alleges his employers’ reimbursement policy fails to reasonably approximate delivery expenses, ultimately causing his effective pay rate to fall below the required minimum wage. Regardless of how many miles the plaintiff drives while making deliveries, the case says, he was reimbursed with $1.05 per delivery until the summer of 2018, when began to receive $1.10. This reimbursement rate is far below the IRS business mileage reimbursement rate, the suit explains, estimating that the defendants “under-reimbursed [the plaintiff] about $1.75 per delivery.”

The suit further argues the plaintiff was deprived of proper time-and-a-half overtime wages due to his out-of-pocket expenses, which, in addition to automobile expenses, included deductions from his wages for the maintenance of work uniforms.