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Second Circuit Addresses Off-The-Clock Work

In Perry et al. v. City of New York, the Second Circuit upheld a large jury verdict in favor of a collective of workers regarding off-the-clock work. In doing so, the Court reaffirmed the principle that employers will...more

Second Circuit: Court Review Needed for FLSA Dismissals Even Without Prejudice

Seyfarth Synopsis: The Second Circuit held that dismissals without prejudice of FLSA claims are subject to the same judicial or agency scrutiny as dismissals with prejudice of FLSA claims....more

Second Circuit: Mere Allegation Of Willfulness Not Enough To Invoke Three-Year Statute Of Limitations

Seyfarth Synopsis: In Whiteside v. Hover-Davis, Inc., the Second Circuit upheld the dismissal of an FLSA claim because the plaintiff failed to allege facts sufficient to invoke the three-year limitations period for willful...more

Second Circuit Lets Collective Action Proceed Where Class Action Fails

Seyfarth Synopsis: The Second Circuit has held that the standard for final FLSA collective action certification is less stringent than the standard for class action certification under Rule 23....more

Small Claims? Low Recovery? Big Fees!

Seyfarth Synopsis: The Second Circuit held that attorneys’ fee awards in FLSA settlements are not limited by principles of “proportionality” between the fees and the amount of the settlement or subject to a 1/3 cap....more

Second Circuit: No Court Review Needed for FLSA Settlements by Offer of Judgment

Seyfarth Synopsis: The Second Circuit held that FLSA settlements pursuant to Rule 68 Offers of Judgment do not require judicial approval.  The Court distinguished such settlements from Rule 41 stipulated dismissals, which...more

New York Minimum Wage and Salary Threshold for Exempt Employees Set to Increase

Seyfarth Synopsis: As they have each year since 2016, the minimum wage and exempt salary threshold will increase for New York employers effective December 31, 2019....more

Keeping it Local: Another Court Denies FLSA Conditional Certification Due to Lack of Personal Jurisdiction

Seyfarth Synopsis: Furthering a recent trend, a judge in the District of Massachusetts denied a motion for conditional certification because there was no personal jurisdiction over non-Massachusetts entities with respect to...more

Don’t Judge A Conditional Certification Motion By Its Cover

A New York federal court once again denied a motion for conditional certification of a nationwide collective action against Barnes & Noble. ...more

NY Attorney General “PAID” Lip Service To DOL Initiative

Seyfarth Synopsis: The U.S. Department of Labor has announced the launch of the Payroll Audit Independent Determination program—or “PAID”— to facilitate the resolution of overtime and minimum wage claims under the FLSA...more

DOL Bids Adieu to Six-Factor Internship Test

Seyfarth Synopsis: The Department of Labor has scrapped its 2010 Fact Sheet on internship status and adopted the more flexible and employer-friendly test devised by Second Circuit....more

New York’s Highest Court: Pre-Certification Settlements Require Classwide Notice

Seyfarth Synopsis: The New York Court of Appeals holds that the state’s class action rules require notice of settlements to be sent to putative class members – even though no class has been certified....more

Interns Flunk The Class

Seyfarth Synopsis: The Second Circuit has upheld summary judgment against magazine interns seeking payment as “employees” under the FLSA. In an end-of-semester decision that may represent the final grade for unpaid interns...more

“Similarly Situated” Seriously Scrutinized by Southern District

Seyfarth Synopsis: A judge in the Southern District of New York held that FLSA off-the-clock claims could not proceed collectively because the employer’s policy enforcement and approval of overtime compensation varied by...more

Money for Nothing! Court Allows Employees to Pursue Lawsuit Despite DOL Settlement

Seyfarth Synopsis: The majority of courts have held that releases of FLSA rights require approval by a court or the US Department of Labor. A recent case in the Southern District of New York highlights a dilemma employers...more

Don’t Judge a Conditional Certification Motion by Its Cover

Seyfarth Synopsis: A New York federal court denied a motion for conditional certification of a nationwide collective action against Barnes & Noble. The ruling highlights that, even though the burden for “first stage”...more

No “Double Dipping”! Second Circuit Rejects Combination of Liquidated Damages Under FLSA and NY Labor Law

Amid the uncertainty concerning the DOL’s enjoined overtime exemption rules and similar state-led efforts to increase the salary threshold, such as in New York, the Second Circuit recently gave employers an early holiday...more

NY DOL To Increase Salary Threshold for Exempt Employees

As we all know, the revisions to the FLSA’s “white collar” exemptions will take effect December 1 and will increase the salary level required for the executive, administrative, and professional exemptions to $913 per week (or...more

SDNY Adopts Pilot Mandatory Mediation Program for FLSA Cases

As we all know, wage and hour litigation continues to soar to record highs. We expect 2016 will be another record year and that the revisions to the white collar exemptions effective December 1st will further increase the...more

In Final Exam, Court Rejects Hearst Interns’ Pay Claims

Unpaid interns for Hearst magazines have been rebuffed again in their effort to be declared eligible to receive wages under the FLSA and the New York Labor Law. In an August 24, 2016 ruling, Judge J. Paul Oetken of the...more

District Court Turns the Other “Cheeks” on Parties’ Proposed Stipulation of Dismissal

Seyfarth Synopsis: A district court judge within the Second Circuit held that, in light of Cheeks v. Freeport Pancake House, court or DOL approval is required for a valid dismissal of FLSA claims with prejudice pursuant to...more

Doing the “Two Step”: Court Denies Second Stage Certification of FLSA Claims

Plaintiffs’ counsel frequently speak of the “low” burden necessary at first stage for conditional certification under the FLSA. However, a recent decision from the Eastern District of New York highlights that plaintiffs may...more

Closure For Second Circuit Intern Case, But Risks Persist Nationally

Spring is around the corner, with summer not far behind, so thoughts naturally turn to the obvious topic: internships. Although the volume of new lawsuits by unpaid interns challenging their status has abated...more

Brokers Take a Bath in FLSA Collective Action

Former brokers of Fordham Financial Management will have to put this one in the “loss” column. Judge Paul Crotty of the Southern District of New York granted Fordham’s motion to decertify the FLSA collective in their lawsuit...more

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