Allen v. Honda Manufacturing Alabama, LLC
1:12-cv-03024
N.D. Ala.Sep 20, 2012Background
- FLSA collective action suit against Honda Manufacturing of Alabama, LLC (HMA) in the Northern District of Alabama by Burroughs, Caldwell, and Blake; conditional certification granted April 6, 2009.
- HMA moved to decertify the collective and dismiss opt-in plaintiffs’ claims (Doc. 154) with briefing and surreplies through mid-2012.
- A related Briggins decertification decision (No. 1:08-CV-1861-KOB) issued March 29, 2012 and served as persuasive authority.
- Court issued show-cause Order on May 2, 2012 requiring plaintiffs to distinguish Briggins; responses filed May 24, 2012 and June 28, 2012.
- Court granted HMA’s motion, decertifying the collective, dismissing opt-ins without prejudice to sue individually by August 20, 2012, and severing Caldwell and Blake into separate actions while Burroughs remains in the original case.
- Severed cases to be consolidated for discovery under 1:08-CV-1239-VEH with filings in that docket.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should the FLSA collective action be decertified? | Plaintiffs argue similarities with Briggins support certification. | Briggins decertification shows lack of similarly situated plaintiffs. | Decertified; not similarly situated. |
| Are opt-in plaintiffs similarly situated across job duties and pay? | Plaintiffs contend common FLSA issues prevail. | Substantial position/department variations prevent common liability. | Not similarly situated; decertification affirmed. |
| Can record-keeping arguments sustain continued collective status? | Record-keeping deficiencies justify continuing collective action. | Anderson burden-shifting not controlling here; records not dispositive. | Rejected; decertification upheld. |
| Should opt-ins be dismissed without prejudice and severed for individual actions? | Possible to preserve rights by individual actions. | Sever and dismiss to avoid prejudice and manageability. | Granted; opt-ins dismissed without prejudice and severed. |
| Whether Briggins decertification analysis should guide this case? | Briggins analysis not controlling. | Briggins is persuasive authority. | Court adopts Briggins decertification framework as persuasive authority. |
Key Cases Cited
- Hipp v. Liberty Nat’l Life Ins. Co., 252 F.3d 1208 (11th Cir. 2001) (two-step approach to FLSA collective action certification (notice stage and decertification))
- Dybach v. State of Fla. Dep’t of Corrections, 942 F.2d 1562 (11th Cir. 1991) (two-part test for determining ‘similarly situated’ in collective actions)
- Cameron-Grant v. Maxim Healthcare Servs., Inc., 347 F.3d 1240 (11th Cir. 2003) (distinguishes FLSA collective actions from Rule 23 class actions)
- Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (U.S. 1946) (record-based burden-shifting; employee can prove hours worked when employer records are inadequate)
- Hoffmann-La Roche, Inc. v. Sperling, 493 U.S. 165 (1989) (benefits and structure of collective actions under § 216(b) balancing; not automatic relief)
- Mooney v. Aramco Servs. Co., 54 F.3d 1207 (5th Cir. 1995) (burden shifting where records are incomplete; reasoning cited in FLSA context)
- McKenna v. Champion Int’l Corp., 747 F.2d 1211 (8th Cir. 1984) (discussion on evidence and inference in wage claims)