Lochridge v. Lindsey Mgmt. Co., No. 14-3799 (8th Cir. 2016)
Annotate this CasePlaintiffs and six others filed suit against Lindsey Management alleging misclassification as exempt employees under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201-219. The jury found in favor of Lindsey Management. On appeal, Lindsey Management challenges the district court's denial of its Bill of Costs in its entirety. Section 216(b) of the FLSA is silent regarding the court's authority when the defendant is a prevailing party under Rule 54(d). Because section 216(b) addresses only an award of costs to a prevailing plaintiff and neither section 216(b) nor any other provision of the FLSA precludes an award of costs to a prevailing defendant, the court concludes that Lindsey Management is not precluded from collecting its costs incurred. The fact that a prevailing party prosecutes its rights under the Federal Rules of Civil Procedure to an award of costs cannot be seen as chilling the flow of litigation. Therefore, the court reversed because Lindsey Management is entitled to a decision whether its Bill of Costs should be awarded under Rule 54(d)(1) without consideration of the FLSA’s silence on the issue of prevailing defendants. Accordingly, the court remanded for the district court to consider whether costs should be awarded under Rule 54(d)(1).
Court Description: Bough, Author, with Colloton and Shepherd, District Judges] Civil case - Fair Labor Standards Act. The Fair Labor Standards Act is silent regarding the awarding of costs under Rule 54(d), and in the face of statutory silence the prevailing party may recover costs; defendant is entitled to a decision whether its Bill of Costs should be awarded under 54(d) without consideration of the Act's silence on the issue of prevailing defendants, and the matter is remanded for a determination of whether costs should be awarded under Rule 54(d)(1).
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