A former delivery driver at a Domino’s Pizza location in central Massachusetts has filed a proposed class action against the owner of several local Domino’s restaurants, accusing him of failing to pay drivers minimum wage. or fully compensate them for their mileage, records show.

Jon Gerhardson, of Chicopee, filed the lawsuit Nov. 5 against Springfield Pie Inc., a franchisee that owns and operates several Domino’s locations in the Springfield area, in Hampden Superior Court, according to legal filings.

In the civil complaint, Gerhardson said he is suing on behalf of “himself and all the other delivery drivers” employed by Springfield Pie over the past few years and who have faced similar alleged mistreatment.

When Gerhardson worked as a driver for Springfield Pie, the company’s reimbursement rate for drivers was “well below the IRS standard rate per mile,” the complaint alleged.

The complaint did not specify how much Gerhardson was compensated for the mileage. IRS documents indicate that “the standard mileage rate for transportation or travel expenses is 67 cents per mile for all business use miles.”

Springfield Pie President Augusto Garcia Jr. did not immediately respond to a request for comment Tuesday.

The lawsuit also alleged that for a period of Gerhardson’s employment, he was paid “at an hourly rate below the basic minimum wage for all hours worked.”

Springfield Pie paid Gerhardson “a service rate for all hours worked despite failing to comply with federal and Massachusetts law regarding notifying the plaintiff of their intent to pay him in this manner,” the complaint states.

The filing did not specify how much Gerhardson was paid.

Under state law, the minimum wage for most workers is $15 an hour, but tipped workers such as restaurant servers and delivery drivers can be paid a “service rate” of $6.75 an hour. Employers must inform workers that they will be paid at the service rate, and if the tips and service rate do not add up to an hourly rate of $15, “the employer must pay the difference,” according to state records.

“Defendant’s treatment of Plaintiff and members of the minimum wage class as tipped employees was unlawful because Defendant failed to comply with Massachusetts notice requirements regarding payment of tipped employees,” the complaint states.

The complaint said the number of drivers who could sue as class members “probably exceeds 100.” They are seeking more than $100,000 in damages.

Springfield Pie had not officially responded to the complaint as of Tuesday. An attorney for Gerhardson did not immediately respond to a request for comment.

The suit comes as Massachusetts voters rejected it last week a bid to raise the minimum wage for tipped workers to $15 an hour.

Opponents argued the ballot measure, known as Question 5, would ultimately cut earnings for 120,000 workers by cutting their tips and spell the demise of companies already struggling with rising ingredient and labor costs of work.

Advocates have long said ending the tipped wage is the first step toward raising wages and labor standards in the restaurant industry. Complaints about wage theft are rife, and the average tipped worker makes 35 percent less than the average wage for all employees nationwide of $31.50 an hour, according to the data. research from UMass Amherst.

This report used material from previous Globe stories. This breaking news story will be updated when more information is released.

Travis Andersen can be reached at [email protected].