## Facts

- Thai immigrant garment workers alleged they were smuggled into the United States and confined at a guarded El Monte, California compound where they were forced to work long hours for little or no pay.
- Plaintiffs alleged restricted freedom of movement, surveillance, threats of harm, and forced living and working conditions amounting to involuntary servitude.
- Defendants included alleged operators of the El Monte garment operation and upstream manufacturers/retailers who allegedly benefitted from low-cost production and helped set prices and schedules.
- Plaintiffs asserted federal and state claims, including wage-and-hour claims, civil rights claims, civil RICO, and state tort and labor claims.
- Motions before the court included: (1) a Rule 12(e) motion for a more definite statement, (2) Rule 12(b)(6) motions to dismiss, (3) a Rule 12(f) motion to strike, and (4) a Rule 56 summary judgment motion by Mervyn’s.

## Issues

1. Whether the amended complaint was so vague or ambiguous that defendants were entitled to a more definite statement under Rule 12(e).
2. Whether certain causes of action premised on federal peonage/involuntary servitude criminal statutes and related conspiracy theories stated a cognizable civil claim.
3. Whether specific allegations or terminology in the complaint should be stricken as scandalous or prejudicial under Rule 12(f).
4. Whether Mervyn’s was entitled to early summary judgment on the ground that it lacked a legally relevant relationship to the workers or sufficient control to support liability.

## Decision

- Denied defendants’ Rule 12(e) motion for a more definite statement.
- Granted in part and denied in part the Rule 12(b)(6) motions to dismiss; dismissed the fourth and fifth causes of action with prejudice.
- Granted in part and denied in part the Rule 12(f) motion to strike; ordered the term “Slave Sweatshop” stricken from the complaint while leaving underlying factual allegations intact.
- Denied Mervyn’s motion for summary judgment without prejudice to renewal after further factual development.

## Legal Principles

- A Rule 12(e) motion is appropriate only when a pleading is so vague or ambiguous that a party cannot reasonably frame a responsive pleading; complexity alone does not justify relief where notice pleading is satisfied.
- Criminal peonage and involuntary servitude statutes generally do not create a standalone private civil cause of action; plaintiffs must proceed through a valid civil vehicle rather than recasting criminal prohibitions as independent civil claims.
- A court may strike redundant, immaterial, impertinent, or scandalous matter under Rule 12(f), including inflammatory terminology, while preserving relevant factual allegations.
- Summary judgment requires the absence of genuine disputes of material fact; where the record is undeveloped and material questions remain (including potential joint-employer control or knowledge), early summary judgment may be denied without prejudice.

## Conclusion

The court allowed most claims concerning alleged forced labor and supply-chain responsibility to proceed past the pleading stage, but it dismissed with prejudice two causes of action grounded in peonage-based civil theories lacking a proper private remedy, required removal of prejudicial rhetoric from the complaint, and declined to grant an upstream retailer early summary judgment given unresolved factual disputes.


Bureerong v. Uvawas, 922 F. Supp. 1450 (C.D. Cal. 1996)