Garrison v. ConAgra Foods, No. 15-1177 (8th Cir. 2016)
Annotate this CaseEvelyn Garrison and ten opt-in plaintiffs filed suit against ConAgra under the Arkansas Minimum Wage Act (AMWA), Ark. Code Ann. 11-4-201, et seq., and the Fair Labor Standards Act (FLSA), 29 U.S.C. 201-219. Plaintiffs alleged that they were misclassified as exempt employees and denied overtime pay. The district court granted summary judgment to ConAgra. The court concluded that ConAgra is entitled to judgment as a matter of law on both the federal and state law claims and affirmed the district court’s grant of summary judgment. In this case, the undisputed facts show that plaintiffs were working in an executive capacity and are exempt from the FLSA overtime pay requirements, as well as the AMWA overtime pay requirements. The court also concluded that a prevailing FLSA defendant is not precluded from recovering costs as a result of Federal Rule of Civil Procedure 54(d) and the silence in 29 U.S.C. 216(b). Therefore, the court vacated the district court’s denial of ConAgra’s motion for costs and remanded to the district court to consider whether ConAgra’s costs should be awarded pursuant to Rule 54(d) and whether costs should be assessed against Plaintiff Garrison and ten opt-in plaintiffs jointly and severally.
Court Description: Bough, Author, with Colloton and Shepherd, Circuit Judges] Civil case - Fair Labor Standards Act. The district court did not err in finding the executive exemption applied to the plaintiffs in this action for overtime pay under the FLSA and the Arkansas Minimum Wage Act; the evidence showed they were employees whose suggestions and recommendations concerning hiring, firing, advancement and other changes of status were given particular weight by their employer; the district court erred in finding defendant was not entitled to costs as a prevailing FLSA defendant - see Lochridge v. Lindsey Mgmt. Co., Inc. 2016 WL 3094040 (8th Cir. June 2, 2016) - and the matter is remanded to the district court for consideration of whether costs should be awarded under Rule 54(d)(1) against the plaintiffs jointly and severally.
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