ST. LOUIS — Two security officers have filed a lawsuit against The City’s Finest (TCF), a Missouri-based security company and its owner alleging violations of state and federal labor laws.
Lamar Tolden and Jadyn Smith, both St. Louis residents and former employees of TCF and its owner, Charles R. Betts, claim in their lawsuit that the company systematically failed to pay them and other security officers the legally required overtime wages for hours worked beyond 40 per week, according to a complaint filed Feb. 4 in U.S. District Court for the Eastern District of Missouri.
The complaint argues that TCF's payroll practices violate both the Fair Labor Standards Act (FLSA) and the Missouri Minimum Wage Law (MMWL).
Tolden and Smith regularly worked well over 40 hours per week, with some weeks exceeding 70 hours, the complaint stated.
Despite this, they say TCF failed to pay them an overtime premium of one-and-a-half times their regular hourly wage, which is required by law.
Tolden, who was hired as an armed security officer in June 2022, reportedly earned a base hourly rate of $25, plus shift differentials for nights and weekends.
Smith’s employment details were not specified in the complaint, but both plaintiffs allege that the company engaged in a pattern of denying legally required overtime pay to its security staff.
“Defendants’ payroll policies and practices were and are in direct violation of the MMWL and the FLSA,” the complaint states.
The lawsuit further alleges that TCF employs approximately 200 security officers and generates an annual revenue of at least $500,000.
The plaintiffs argue that the company’s size and resources should have enabled it to comply with wage laws, yet it “willfully failed” to do so.
The lawsuit directly names Betts, the owner and founder of TCF, as a defendant, alleging that he exercised direct control over the company’s employment policies.
Plaintiffs claim that Betts had the authority to hire and fire employees, set work schedules, determine wages, and oversee TCF’s financial operations.
As such, the complaint asserts that Betts is personally responsible for the alleged wage violations, stating that his level of control classifies him as an "employer" under the FLSA.
During their employment, both Tolden and Smith claim they repeatedly questioned why they were not receiving overtime pay, yet TCF allegedly failed to correct its practices.
The lawsuit describes the company's failure to respond to these complaints as evidence of willful noncompliance with wage laws.
“Defendants had multiple opportunities to rectify their noncompliance with federal and state wage laws but failed to do so,” the complaint states.
Tolden and Smith are seeking compensation for unpaid wages, liquidated damages, and punitive damages.
They are also requesting a declaratory judgment that TCF’s practices violated labor laws, as well as an order for the company to cover their legal fees and any other relief deemed appropriate by the court.
The lawsuit highlights ongoing concerns about wage theft and labor law violations in the private security industry, where officers often work long hours under demanding conditions.
Tolden and Smith are represented by Alan G. Crone of The Crone Law Firm in Memphis, Tenn.
The plaintiffs' attorneys did not return to requests for comment before publication.
TCF has not yet issued a public response to the lawsuit.
U.S. District Court for the Eastern District of Missouri, Eastern Division case number: 4:25-cv-00141