Vallone v. CJS Solutions Group, LLC, No. 20-2874 (8th Cir. 2021)
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Plaintiffs filed suit against CJS Solutions, a Florida entity doing business as The HCI Group, in the District of Minnesota. Plaintiffs moved to certify a collective action under the Fair Labor Standards Act (FLSA). The putative class of plaintiffs was composed of all HCI employees hired on a per-project basis who were not paid wages for out-of-town travel to and from remote project locations. After the district court conditionally certified a collective action limited to claims arising out of travel to and from Minnesota, it granted summary judgment for HCI on the ground that plaintiffs were not employees when traveling.
The Eighth Circuit affirmed, concluding that the district court did not err in finding defendant had not waived its jurisdictional defense to plaintiffs' claims for certification of collective actions covering all of defendant's employees for all of their travel time anywhere in the United States; the district court properly excluded all claims with no connection with the forum state of Minnesota; and, in regard to the out-of-town travel claims, the district court did not err in finding that two plaintiffs were not employees when traveling and that defendant had no obligation to pay for their time.
Court Description: [Colloton, Author, with Wollman and Kobes, Circuit Judges] Civil case - Fair Labor Standards Act. The district court did not err in finding defendant had not waived its jurisdictional defense to plaintiffs' claims for certifiction of collective actions covering all of defendant's employees for all of their travel time anywhere in the U.S.; the district court properly excluded all claims with no connection to Minnesota; with respect to plaintiffs' claims for their out-of-town travel, the district court did not err in finding the two plaintiffs were not employees when traveling and that defendant had no obligation to pay for their time. [ August 17, 2021 ]
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