Tran v. Alphonse Hotel Corp.
United States Court of Appeals for the Second Circuit
281 F.3d 23 (2d Cir. 2002)
On October 10, 1991, Tran (plaintiff) sued his former employers, The Carter Hotels and Hotel Kenmore (defendants), alleging that they failed to pay him sufficient wages under the Fair Labor Standards Act (FLSA). Tran later discovered evidence suggesting that the defendants had bribed union officials in order to pay their employees less than the union rate. Based on this evidence, Tran moved to amend his complaint to add a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO) on July 8, 1997. The United States District Court for the Southern District of New York granted the motion, finding that although the statute of limitations on the RICO claim had expired, the RICO claim related back to the FLSA claim in the original complaint. The district court ultimately found in favor of Tran. The defendants appealed on the grounds that the RICO claim did not relate back to the original complaint.
Rule of Law
Holding and Reasoning (Katzmann, J.)
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