News & Analysis as of

Class Certification Wage and Hour Collective Actions

Seyfarth Shaw LLP

The Facts Matter: Publix Defeats Certification of Off-The-Clock Assistant Manager Claims

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Advancing the trend of courts unwilling to rubber stamp the conditional certification of FLSA collective actions, Publix developed an early record of evidence that—when properly scrutinized—warranted the denial of collective...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Seventh Circuit Joins Third, Sixth, and Eighth Circuits in Limiting Exercise of Personal Jurisdiction in FLSA Collective Actions

On August 16, 2024, the Seventh Circuit Court of Appeals weighed in on whether out-of-state plaintiffs must satisfy personal jurisdiction requirements to participate in a collective action under the Fair Labor Standards Act...more

Seyfarth Shaw LLP

From Leniency to Scrutiny: The New FLSA Certification Landscape

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Seyfarth Synopsis: As reported by Seyfarth, the Fifth Circuit’s January 2021 decision in Swales v. KLLM Transport Services, LLC and the Sixth Circuit’s May 2023 decision in Clark v. A&L Homecare and Training Center, et al....more

Proskauer - California Employment Law

January 2024 California Employment Law Notes

A Single Incident Of Harassing Conduct May Create A Hostile Work Environment - Beltran v. Hard Rock Hotel Licensing, Inc., 97 Cal. App. 5th 865 (2023) - Stephanie Beltran, a server at the Hard Rock Hotel in Palm...more

BakerHostetler

A Welcome Sea Change For Employers Defending FLSA Collective Action Cases

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A major change in Fair Labor Standards Act (FLSA) wage and hour jurisprudence has taken place, with BakerHostetler at the helm. In Clark, et al. v. A&L Home Care & Training Center, the Southern District of Ohio conditionally...more

Troutman Pepper Locke

EDVA Judges Wade Into Circuit Split Over Certifying FLSA Collective Actions

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In an August 11 decision, Judge Henry Hudson of the EDVA conditionally certified a class of food service workers employed by a federal contractor at Fort Pickett who sued for unpaid overtime pay under the Fair Labor Standards...more

Polsinelli

The Bar Is Low – But It Does Exist: A Reminder that Defeating (or Limiting) Conditional Certification Is Not Impossible

Polsinelli on

In a recent case from the District of Colorado, a federal judge made clear that (at least in the Tenth Circuit) the first step of conditional certification is not just a rubber stamp to move on to the next stage of litigation...more

Constangy, Brooks, Smith & Prophete, LLP

Sixth Circuit adopts stricter standard for FLSA collective action notices

For years, litigation under the Fair Labor Standards Act has grown exponentially. In 2018 there were 8,824 FLSA lawsuits filed, in contrast with only 3,496 in 2008. A leading factor driving this trend is the near automatic...more

FordHarrison

Sixth Circuit Rejects the Traditional Two-Step Conditional Certification Process in FLSA Collective Actions

FordHarrison on

Executive Summary: The two-step conditional certification process in Fair Labor Standards Act (FLSA) collective action lawsuits, known as the Lusardi standard, has been the law of the land for over 30 years. The conditional...more

Jackson Lewis P.C.

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

Jackson Lewis P.C. on

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

Dinsmore & Shohl LLP

Sixth Circuit Rejects Two-Step Collective Certification Process in FLSA Suits

Dinsmore & Shohl LLP on

In a welcomed change to a class certification process that has long favored plaintiffs, the Sixth Circuit’s May 19, 2023 decision in Clark/Holder v. A&L Homecare and Training Center, LLC adopts a new standard for certifying...more

Polsinelli

Another Circuit Drops 2-Step FLSA Certification Process and Adopts Heightened Notice Standard for Collective Actions

Polsinelli on

On May 19, 2023, the United States Court of Appeals for the Sixth Circuit became the second federal appeals court to heighten the standard for plaintiffs to obtain court-authorized notice to potential plaintiffs in Fair Labor...more

Seyfarth Shaw LLP

Eastern District of Virginia Judge Rejects Two-Step Conditional Certification Process for FLSA Collective Actions

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Seyfarth Synopsis: In what could become a trend, Judge T.S. Ellis, III recently broke with other courts in the Eastern District of Virginia when he rejected the two-step conditional certification process commonly used in FLSA...more

Epstein Becker & Green

Federal Court in Virginia Adopts One-Step Approach to FLSA Collective Action Certification

Epstein Becker & Green on

A little over two years ago, the U.S. Court of Appeals for the Fifth Circuit became the first federal appellate court in the country to reject the widespread and longstanding two-step approach of first “conditionally”...more

Tucker Arensberg, P.C.

Inconsistent Practice of Salary Schedule Placement for New Employees Can Lead to Equal Pay Claim

Tucker Arensberg, P.C. on

Rebecca Cartee-Haring v. Central Bucks School District, Civil Action No. 20-1995 (E.D. Pa. 8/24/22) (A federal court grants certification of a collective action by female teachers pursuing an Equal Pay Act claim for...more

Jackson Walker

Impact of the Fifth Circuit’s Swales Decision on the FLSA Collective Action Certification Process

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Employers confronted with Fair Labor Standards Act (FLSA) claims as to their operations in Texas, Louisiana, or Mississippi should take note of a new decision by the United States District Court for the Northern District of...more

Bradley Arant Boult Cummings LLP

You Can’t Put the Trial Cart Before the Certification Horse in FLSA Hybrid Wage-and-Hour Case; Circuit Court Rejects Trial Court’s...

When a company faces a Fair Labor Standards Act (FLSA) collective action there are two main components to address: (1)You Can’t Put the Trial Cart Before the Certification Horse in FLSA Hybrid Wage-and-Hour Case; Circuit...more

Seyfarth Shaw LLP

Third Circuit Puts The Kibosh on Hybrid Hijinks

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Seyfarth Synopsis: Plaintiffs asserting federal and state wage and hour claims in one action often pursue both class certification of state claims under Rule 23 and collective action certification under the FLSA. In that...more

Troutman Pepper Locke

Fifth Circuit Adopts More Stringent Approach to Collective Action Certification Under the FLSA

Troutman Pepper Locke on

On January 12, 2021, the United States Court of Appeals for the Fifth Circuit issued its opinion in the case of Swales v. KLLM Transport Services, L.L.C., drastically changing the landscape of wage and hour litigation there...more

Seyfarth Shaw LLP

Did the 7th Circuit Just Provide a New Avenue to Defeat Certification of a State Law Overtime Claim?

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Seyfarth Synopsis: The Seventh Circuit Court of Appeals last week affirmed a district court’s denial of class certification of a state overtime claim on numerosity grounds, reasoning that the touchstone for that element is...more

BakerHostetler

Denial of Conditional Certification Highlights Importance of Handbook Policies

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A recent decision from the Eastern District of Wisconsin serves as a strong reminder that well-crafted handbook policies can sometimes save the day for employers in proposed Fair Labor Standards Act collective actions....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Party of One: Collective Action Against Outback Steakhouse Denied due to Lack of Personal Jurisdiction

The U.S. District Court for the District of Massachusetts denied conditional class action certification in a case involving a front of house (FOH) manager suing Outback Steakhouse for unpaid overtime under the Fair Labor...more

Seyfarth Shaw LLP

15th Annual Workplace Class Action Litigation Report

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Seyfarth Synopsis: At 852 pages, Seyfarth’s 15th Annual Workplace Class Action Litigation Report analyzes 1,453 rulings and is our most comprehensive Report ever. ...more

Fox Rothschild LLP

FLSA Proposed Class Cut By Judge Who Found Dissimilarities Among Workers

Fox Rothschild LLP on

Often, when a class of workers petitions for conditional certification in FLSA collective action, and such certification is granted, it usually is for the entire class being asked for. Sometimes it is not and when that...more

Fisher Phillips

Gig Worker’s Hopes Of Arguing Case In Court Are Dashed By Arbitration Agreement

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A delivery driver for gig economy company DoorDash has been ordered by the 5th Circuit Court of Appeals to take his misclassification case to a private arbitrator instead of court pursuant to a valid arbitration agreement he...more

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