Minnesota Living Assistance v. Peterson, No. 17-2658 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's decision to abstain, and held that the district court correctly determined that preemption was not facially conclusive and no exception to Younger abstention applied. In this case, Baywood filed suit against the Commissioner and DLI, alleging that the Fair Labor Standards Act (FLSA) preempted the Minnesota Fair Labor Standards Act (MFLSA) and thus Baywood need not pay state penalties for any MFLSA violation. However, in a previous suit, DLI brought an administrative action against Baywood for failing to pay overtime compensation in violation of the MFLSA.
Court Description: Gruender, Author, with Erickson and Grasz, Circuit Judges] Civil case - Fair Labor Standards Act. An administrative action seeking to determine whether plaintiff failed to pay required overtime due under the Minnesota Fair Labor Standards was pending before the Minnesota Department of Labor and Industry when plaintiff brought this action seeking to declare the Minnesota act was preempted by the Fair Labor Standards Act and to enjoin further proceedings before the Minnesota Department of Labor; held, the district court did not abuse its discretion in applying the Younger doctrine and determining it should abstain and dismiss the case.
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