White v. U.S. Corrections, LLC, No. 19-51074 (5th Cir. 2021)Annotate this Case
Plaintiff, on behalf of herself and other employees, filed suit against her former employer, US Corrections, L.L.C. (USC), and two other entities, alleging an overtime-pay claim and a recordkeeping claim under the Fair Labor Standards Act (FLSA). The district court dismissed the claims and entered judgment in favor of the employer and the company's payroll administrator.
The Fifth Circuit agreed with the district court that the Motor Carrier Act's (MCA) exemption governs plaintiff's job with the employer. The court explained that the district court correctly construed the law to determine that the MCA exemption governs the relationship between plaintiff and USC, irrespective of Jeanna's Act and its implementing regulations. However, the court nonetheless concluded that the district court erred in applying the MCA exemption to foreclose the otherwise plausible FLSA overtime-pay claim alleged by plaintiff in her complaint, at least at the pleading stage. Accordingly, the court reversed and remanded for further proceedings.