HR Management & Compliance

Supreme Court Declines to Review Two FLSA Cases

The U.S. Supreme Court announced Oct. 6 that it would not review two Fair Labor Standards Act rulings. The cases dealt with misclassification and compensable working time.

In the misclassification case, the 9th U.S. Circuit Court of Appeals held that the City of Los Angeles owed fire department dispatchers and paramedics assigned to air ambulance helicopters overtime after misclassifying them under the FLSA’s firefighter exemption, often called the Section 207K exemption. It incorrectly considered those employees to be “engaged in fire protection.”

The 9th Circuit affirmed the district court’s decision to calculate damages using the three-year statute of limitations for a willful FLSA violation. (Haro v. City of Los Angeles, 745 F.3d 1249 (9th Cir. 2014)). See 9th Circuit Chides LA for Repeat ‘Willful’ FLSA Misclassifications for the full story.

In the compensable working time case, the 4th Circuit reversed a jury verdict for poultry plant employees, finding that the workers’ collective bargaining agreement trumped other pay agreements. Despite being told they would be paid for all the time they were clocked in, the workers’ CBA stated that they would be paid only for time spent on the production line. Therefore, they were not entitled to back pay for time spent donning and doffing gear, the court ruled.

The federal Labor Management Relations Act required that the CBA’s provisions be honored, it determined. The workers’ allegation that they had individual contracts undermines the CBA’s role as the exclusive contract for the payment of wages, the court continued. This approach “cannot be accepted without doing serious damage to the system of collective bargaining because, at bottom, the plaintiffs seek to displace the CBA that established the terms and conditions of their employment and to replace it with what they understood to be Columbia Farms’ individual agreements … Obviously, this theory would inappropriately usurp the CBA’s federally protected role” (Barton v. House of Raeford Farms, Inc., d/b/a Columbia Farms, Inc., 745 F.3d 95 (4th Cir. 2014)). For the full story, see Court Reverses Compensable Time Verdict for Poultry Workers.