Braaten v. Slipstream Group
- David Doty
- 0:25-cv-02286
- U.S. District Court · District of Minnesota
- 4
In Braaten v. Slipstream Group, Inc., Judge Doty denied Slipstream's motion for judgment on the pleadings, allowing Erin Braaten's whistleblower, wage, and contract claims to proceed because her allegations were sufficient at this early stage of the case.
Employees who report potential wage law violations to their employers and are subsequently terminated may be interested in this ruling. It also affects employers defending early-stage dismissal motions in whistleblower and wage-payment cases in the District of Minnesota.
What happened
In Braaten v. Slipstream Group, Inc., Erin Braaten was hired by Slipstream Group as its Chief People Officer in October 2024. After receiving her first paycheck, she believed Slipstream had improperly calculated her pay by prorating her salary in a way that violated the federal Fair Labor Standards Act and related Minnesota state wage laws. She reported her concerns internally to company leadership, but Slipstream — with help from outside lawyers — concluded its pay practices were lawful and fired Braaten on December 9, 2024, citing her 'confrontational manner.'
Braaten sued Slipstream in Minnesota state court, and Slipstream moved the case to federal court. She claims Slipstream fired her in retaliation for reporting legal violations (under Minnesota's whistleblower law and wage payment law), that the company breached her employment contract, and that it failed to pay her wages as required by Minnesota law. Slipstream filed a motion for judgment on the pleadings — a request that the court rule in its favor based solely on what the written court filings say, without any factual investigation.
Judge Doty denied Slipstream's motion. The court explained that at this early stage it must accept Braaten's factual allegations as true, and that her claims are plausible enough to move forward. The court noted that whether Slipstream's pay practices actually violated the law is a question that cannot be resolved without a proper factual record. While Judge Doty remarked that Braaten's claims 'may not ultimately be viable,' that determination must wait for a fuller record. The case will continue.
The detailed version
Case: Braaten v. Slipstream Group, Inc., Civil No. 25-2286 (D. Minn.) Judge: David S. Doty, United States District Court Judge, District of Minnesota Decision Date: October 29, 2025
Background Erin Braaten was hired as Chief People Officer — a human resources leadership role — at Slipstream Group, Inc. on October 8, 2024, at an annual salary of $155,000 paid semi-monthly. She began work on October 28, 2024. Her first paycheck, received November 7, 2024, was lower than she expected. Braaten believed Slipstream had improperly prorated (proportionally reduced) her salary, potentially violating the Fair Labor Standards Act (FLSA) — the federal law setting minimum wage and overtime standards — and related Minnesota state wage laws.
Braaten reported her concerns to Slipstream's CEO, Chief Financial Officer, Controller, and General Counsel Tim Mathison. Mathison conducted a risk assessment and, with outside counsel, concluded that Slipstream's proration practices complied with both federal and state law. Braaten, drawing on her industry experience, disagreed. She continued to assert that Slipstream had improperly prorated her paycheck and also that Slipstream had failed to provide her with required wage statement notices or earnings statements. Slipstream investigated her allegations and again concluded it had paid her correctly. On December 9, 2024, Slipstream terminated Braaten's employment, citing her 'confrontational manner.'
Braaten filed suit in Ramsey County District Court (Minnesota state court) on May 2, 2025. Slipstream timely removed the case to federal court. Braaten's complaint asserts four claims: (1) retaliation under the Minnesota Whistleblower Act; (2) retaliation under the Minnesota Payment of Wages Act; (3) breach of her employment contract; and (4) failure to pay wages in violation of the Minnesota Payment of Wages Act.
Motion and Legal Standard Slipstream moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). A motion for judgment on the pleadings is a request that the court rule in the moving party's favor based solely on the allegations contained in the complaint and answer, without any discovery or factual development. The court applies the same standard as a motion to dismiss under Rule 12(b)(6): the complaint must contain sufficient factual allegations, accepted as true, to state a claim that is 'plausible on its face.' The court cited Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) as controlling precedent.
Ruling Judge Doty denied Slipstream's motion. The court observed that both parties appeared to agree that the viability of Braaten's claims hinges on whether Slipstream's payroll practices actually complied with applicable law. The court acknowledged that Braaten's claims 'may not ultimately be viable,' but concluded that this question cannot be resolved at the pleadings stage without a factual record. Taking Braaten's allegations as true, as required at this stage, she has plausibly alleged claims against Slipstream. The motion for judgment on the pleadings (ECF No. 12) was denied. The case will proceed to further litigation.
Reviewer note from the AI+
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