Jenkins v. S. David Anton, PA, No. 17-13073 (11th Cir. 2019)Annotate this Case
The Eleventh Circuit affirmed the district court's judgment in favor of defendant in an action alleging unpaid overtime wages under the Fair Labor Standards Act (FLSA). In this case, plaintiff alleged that her employer failed to pay her over 700 hours of overtime for her work at his law office.
The court held that the district court did not abuse its discretion by denying relief under Federal Rule of Civil Procedure 59 to alter or amend the judgment where the evidence was newly discovered, the outcome of the trial would have been the same, or there were no manifest errors made by the district court; the district court did not abuse its discretion by denying relief under Rule 60 based on a newly discovered email; the district court did not misapply the burden-shifting framework set out in Anderson v. Mt. Clemens Pottery Co., when it found that plaintiff did not prove she worked overtime; and the civil plain error rule barred the court's review of the district court's sua sponte failure to recuse.