Bell v. Southeastern Pennsylvania Transportation Authority
733 F.3d 490
| 3rd Cir. | 2013Background
- Operators allege SEPTA failed to compensate time spent on pre-trip Reporting Tasks (~10 minutes) before departure.
- Operators allege CDL Inspections (~15 minutes) occur pre-trip and are unpaid, affecting overtime calculations under FLSA.
- CBAs with CTDO, TWU, and UTU contain pre-start compensation provisions but are not claimed to be violated by SEPTA.
- District Court dismissed, holding the FLSA claim required interpretation of CBAs and arbitration under grievance provisions.
- Appellate court concludes FLSA claim does not inherently require CBA interpretation and arbitration at the LMRA level.
- Court vacates the District Court’s dismissal and remands for further proceedings consistent with this opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the FLSA overtime claim depend on CBA interpretation? | Operators contend FLSA rights exist independently of CBAs. | SEPTA argues FLSA claim depends on CBA interpretation per Vadino. | No; FLSA claim independent of CBA interpretation. |
Key Cases Cited
- Barrentine v. Arkansas-Best Freight System, Inc., 450 U.S. 728 (U.S. 1981) (FLSA rights take precedence over conflicting CBA terms)
- Vadino v. A. Valey Engineers, 903 F.2d 253 (3d Cir. 1990) (FLSA claims tied to CBA interpretation must be arbitrated)