Goonewardene v. ADP, LLC

Summary

The court held that an employee may not sue an employer's payroll service provider for unpaid wages under a third-party-beneficiary theory because employees are ordinarily not the contracting parties' intended beneficiaries and employee enforcement is inconsistent with the contract's objectives and reasonable expectations. The court also held that the payroll provider owed no tort duty of care supporting negligence or negligent-misrepresentation claims because existing wage remedies against the employer adequately protect employees and additional liability would create substantial policy and litigation burdens. The judgment was reversed insofar as it allowed those claims to proceed, and the matter was remanded with directions to affirm the judgment for ADP.