Chad Lochridge v. Lindsey Management Co.
824 F.3d 780
8th Cir.2016Background
- Seven employees sued Lindsey Management under the FLSA alleging misclassification as exempt employees; a jury returned a verdict for Lindsey Management.
- District court had conditionally certified two classes; the Salaried Class was later decertified and pursued individual claims; the Hourly Class settled.
- After prevailing at trial, Lindsey Management filed a Bill of Costs under Fed. R. Civ. P. 54(d)(1) seeking $22,687.51.
- Plaintiffs objected; the district court denied the Bill of Costs, reasoning the remedial nature of the FLSA and its silence on awarding costs to prevailing defendants counseled denial.
- Lindsey Management appealed, arguing the district court abused its discretion by failing to articulate grounds to overcome the presumption in favor of awarding costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 216(b) of the FLSA precludes awarding costs to a prevailing defendant under Rule 54(d)(1) | FLSA is remedial and its silence indicates defendants should not recover costs | Rule 54(d)(1) presumes costs to prevailing party; § 216(b) is silent and does not preclude defendant recovery | Vacated district court; § 216(b) silence does not bar costs to prevailing defendants; remand for discretionary consideration under Rule 54(d)(1) |
| Whether the district court abused its discretion by denying costs without adequate justification | N/A (plaintiffs urged discretion be exercised to deny) | District court failed to articulate grounds sufficient to overcome the Rule 54(d)(1) presumption | Reversed in part: district court must reconsider and explain its exercise of discretion on remand |
Key Cases Cited
- Marx v. General Revenue Corp., 133 S. Ct. 1166 (2013) (statutory silence does not displace Rule 54(d)(1) discretion to award costs)
- Martin v. DaimlerChrysler Corp., 251 F.3d 691 (8th Cir. 2001) (standard of abuse-of-discretion review for awarding costs)
- Taniguchi v. Kan Pacific Saipan, Ltd., 132 S. Ct. 1997 (2012) (Rule 54(d) vests courts with discretion to award costs)
- Reger v. The Nemours Found., Inc., 599 F.3d 285 (3d Cir. 2010) (awarding costs deters meritless litigation and is within courts’ discretion)