Facts

Natalya Shuvalova and Elizabeth Shuvalova, mother and daughter, sued Joseph Cunningham and Daniel Cunningham, father and son, alleging involuntary servitude in violation of the Trafficking Victims Protection Reauthorization Act (TVPRA). Plaintiffs also alleged violations of the Fair Labor Standards Act (FLSA) and the California Labor Code. Plaintiffs alleged that they were denied minimum wage as required under FLSA and the Labor Code, including failure to pay minimum wage and overtime, among others.

Natalya and Joseph met through a computer dating service in October 2005, and began a two-year relationship prior to Natalya and Elizabeth's arrival in the U.S. in 2008 following Joseph's proposal. Plaintiffs began living with Joseph at his property in Clearlake with Joseph's adult son, Daniel. Natalya and Joseph married in May 3, 2008.

Plaintiffs claimed that defendant, and his adult son, fraudulently lured them from Russia to the U.S. and induced Natalya to marry one defendant and then forced plaintiffs into involuntary servitude at defendant's property in Clearlake, California. Plaintiffs claimed that defendants' verbal and physical threats forced them to perform heavy, outdoor labor on the property.

Defendants moved to dismiss the entire complaint.

Result

The court granted defendants' motion and dismissed plaintiffs' claims. The court held that plaintiffs may rely on their FLSA and Labor Code claims if they prevail on their TVPRA claims, but the FLSA and Labor Code claims cannot proceed as stand-alone cases premised on fraudulent inducement to marry.