New York City says Chipotle owes workers $150 million in back pay for hundreds of thousands of violations of the city’s Fair Workweek Law, which was enacted in 2017 to make fast-food workers’ schedules more predictable and less subject to last-minute changes. Each violation of the law is subject to a $500 penalty, meaning that Chipotle is additionally on the hook for $300 million in civil penalties.

The complaint, filed by the Department of Consumer and Worker Protection at the Office of Administrative Trials and Hearings on April 28, covers the period from when the Fair Workweek Law went into effect in November 2017, to December 2019, when the city filed an initial suit over violations. The recent complaint says that while the fast-casual chain “made some efforts to come into compliance beginning in September 2019, it remains out of compliance in significant ways.”

“The city is filing this lawsuit so that our lives change, and our treatment at these jobs changes,” says Teodora Flores, through a translator. Flores has worked at the 350 5th Avenue Chipotle since February 2018. She says that when she first began working at Chipotle, she did not know about the provisions in the Fair Workweek Law. These include workers’ right to know their schedule two weeks in advance, with companies mandated to pay workers a premium if they adjust schedules in that two-week period. A worker also cannot be scheduled for “clopening” — working a closing shift one day and an opening shift the next — without that worker’s written consent and a $100 pay premium.