Edwards v. 4JLJ, LLC, No. 19-40553 (5th Cir. 2020)Annotate this Case
Plaintiffs filed suit against 4JLJ under the Fair Labor Standards Act (FLSA), alleging that 4JLJ violated the FLSA's overtime wage mandates. Plaintiffs argued that the stage bonus and performance bonus should have been included in the "regular rate" for the purposes of overtime calculation. After the jury's verdict, plaintiffs filed two identical motions for judgment as a matter of law, which were both denied. The district court awarded sanctions to the plaintiffs over a contentious discovery dispute.
The Fifth Circuit held that the performance bonuses—but not the stage bonuses—should have been included in the regular rate as a matter of law. In this case, a reasonable jury could not have concluded that 4JLJ maintained discretion over the amount of performance bonuses, and thus the performance bonuses were nondiscretionary under the FLSA. Accordingly, the court reversed and remanded for the district court to consider all relief warranted. The court affirmed the sanctions award, holding that the district court did not abuse its discretion and that 4JLJ's arguments on cross-appeal are unavailing.
The court issued a subsequent related opinion or order on September 21, 2020.