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Another Circuit Rules Bristol-Myers Applies to FLSA Collective Actions, Bars Out-of-State Opt-Ins

The U.S. Court of Appeals for the Seventh Circuit joins a growing number of federal circuits to hold the U.S. Supreme Court’s 2017 decision in Bristol-Myers Squibb v. Superior Court, that sharply limited the use of nationwide...more

Sixth Circuit Adopts New Standard to Decide Whether to Send Notice to Potential FLSA Opt-Ins

In a highly anticipated decision, the U.S. Court of Appeals for the Sixth Circuit has ruled it will not use the lenient, two-step procedure in deciding whether to authorize sending notice of a collective action to other...more

Chipping Away at Two-Step Conditional Certification in FLSA Collective Actions

A federal district court located within the jurisdiction of the U.S. Court of Appeals for the Fourth Circuit has adopted the heightened standard for certification of a collective action under the Fair Labor Standards Act...more

U.S. Supreme Court Declines to Consider Whether Bristol-Myers Applies to Collective Actions

The U.S. Supreme Court has declined to settle the circuit split on whether its 2017 decision in Bristol-Myers Squibb Co. v. Superior Court of Cal. applies to collective actions brought under the Fair Labor Standards Act...more

Class Action Trends Report Winter 2023

In this issue of the Jackson Lewis Class Action Trends Report, we welcome the New Year and look back at the most significant developments affecting employment class and collective action litigation in 2022. We also look ahead...more

Has Lynn’s Food Grown Stale? Courts Increasingly Question Obligation to Review FLSA Settlements

For 40 years, the majority of federal courts have followed the holding of Lynn’s Food Stores, Inc. v. U.S., 679 F.2d 1350 (11th Cir. 1982), that FLSA claims may be settled only through approval by the U.S. Department of Labor...more

Bristol-Myers Decision Applies to Plaintiffs in FLSA Collective Actions, Third Circuit Holds

Since the U.S. Supreme Court’s 2017 decision in Bristol-Myers Squibb Co. v. Superior Court of Cal., 137 S. Ct. 1773, limiting the scope of a court’s jurisdiction over out-of-state claims, federal courts have grappled with...more

Are Non-Emergency Transport Providers Employees or Independent Contractors? Jury Questions Exist, Eighth Circuit Holds

Reversing summary judgment in favor of the U.S. Department of Labor (DOL), the Eighth Circuit has held that jury questions exist as to whether the defendant employed drivers who provide non-emergency medical transport...more

FAA’s Transportation Worker Exception Covers Airline Ramp Agents, U.S. Supreme Court Holds

Individuals employed as ramp workers who frequently handle cargo for an airline are “transportation workers” exempt from the Federal Arbitration Act (FAA), the U.S. Supreme Court has held. Southwest Airlines Co. v. Saxon, No....more

North Carolina Federal Court Holds It Lacks Jurisdiction Over Claims Of Out-Of-State Opt-Ins

In the latest court ruling to address personal jurisdiction over out-of-state opt-in plaintiffs in Fair Labor Standards Act collective actions, a federal district court in North Carolina held that it lacked jurisdiction over...more

Appeals Court Creates Circuit Split on Whether Bristol-Myers Applies to Collective Actions

In its 2017 decision in Bristol-Myers Squibb Co. v. Superior Court of Cal., the U.S. Supreme Court held that a state court could not exercise specific personal jurisdiction over nonresident plaintiffs’ claims against a...more

Build Back Better Act Update: Class Waiver Provisions Gone, Penalty Increases Remain

The Senate Committee on Health, Education, Labor, and Pensions has released its version of the Build Back Better bill and it does not contain the provision regarding class or collective action waivers in the version passed by...more

Fifth Circuit Rejects Two-Step Approach for Certifying FLSA Collective Actions

On “how stringently, and how soon, district courts should enforce [Fair Labor Standards Act] Section 216(b)’s ‘similarly situated’ mandate” when considering motions for certification of collective actions, the U.S. Court of...more

Department Of Labor Issues Final Independent Contractor Rule

The Department of Labor’s (DOL) Wage and Hour Division has formally released a Final Rule defining “independent contractors” under the Fair Labor Standards Act (FLSA). The regulation provides that “an individual is an...more

Class Action Trends Report Fall 2020

As the COVID-19 pandemic continues to alter work lives in profound ways, employers are confronted with additional liability risks. The pandemic has created a wave of litigation that is unlikely to ebb until well after the...more

Connecticut Department Of Labor Issues Final Regulations On State’s New Tip Credit Statute

The Connecticut Department of Labor (CTDOL) has issued new and revised regulations regarding the state’s tip credit law. The final regulations greatly clarified some aspects of the existing regulatory language that had led to...more

U.S. Department Of Labor Proposes New Rule To Streamline Independent Contractor Analysis

The U.S. Department of Labor (DOL) has issued a new proposed regulation setting forth the proper standard for determining a worker’s status as an “independent contractor” under the Fair Labor Standards Act (FLSA)...more

The Meaning Of “Similarly Situated” Is Teed Up For SCOTUS

The U.S. Supreme Court has been asked to fill a gaping hole in our Fair Labor Standards Act (FLSA) jurisprudence: What, precisely, is meant by “similarly situated,” as set forth in 29 U.S.C. 216(b)? The request comes in a...more

Fifth Circuit: Arbitrator Properly Interpreted Arbitration Agreement To Allow For Collective Claims

Consistent with the terms of the arbitration agreement at issue, an hourly fuel tech and driver is entitled to arbitrate collective claims alleging that his employer violated the Fair Labor Standards Act (FLSA), the federal...more

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