2011 WL 291424
D. Minn.2011Background
- Lawson Software employed consultants (BCs, SCs, TCs) who traveled ~80% and advised on Lawson software implementations.
- The Court conditionally certified an FLSA class in 2009, later decertified it in 2011 and dismissed opt-ins without prejudice.
- Plaintiffs sought three FLSA subclasses (BC, SC, TC), but the court found substantial dissimilarities in duties and settings.
- Named Plaintiffs Cruz, Littlejohn, Winn, Preston, and Roepke pursued FLSA claims; Roepke additionally pursued MFLSA claims.
- Lawson moved for decertification and summary judgment; the Court granted decertification, then granted summary judgment on named-plaintiffs’ claims under the administrative exemption.
- The Court held the administrative exemption applicable to all five named plaintiffs, precluding MFLSA overtime, and dismissing unjust enrichment as preempted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FLSA class should be decertified. | Cruz argues claims are similarly situated as to policy and practice. | Lawson contends duties vary; individualized defenses/pretexts predominate. | Decertified; opt-in plaintiffs dismissed without prejudice. |
| Whether named plaintiffs are exempt under the administrative exemption. | Plaintiffs contend exemptions cannot be resolved collectively. | Lawson asserts administrative exemption applies to all five based on duties and discretion. | Administrative exemption applies to all five named plaintiffs. |
| Whether Roepke’s MFLSA claims survive, given administrative exemption. | Roepke asserts MFLSA overtime rights alongside FLSA claims. | MFLSA is aligned with FLSA exemptions and should be dismissed. | Grants summary judgment on Roepke’s MFLSA overtime claim. |
| Whether Roepke’s MFLSA recordkeeping claim survives. | Recordkeeping claims should extend to exempt employees. | Exempt employees are not subject to MFLSA recordkeeping requirements. | Dismissed; MFLSA recordkeeping claim denied. |
| Whether unjust enrichment claims survive in light of FLSA preemption. | Unjust enrichment may provide alternative basis for damages. | FLSA preempts unjust enrichment where duplicative. | Preempted; unjust enrichment claim dismissed. |
Key Cases Cited
- Nerland v. Caribou Coffee Co., Inc., 564 F.Supp.2d 1010 (D.Minn. 2007) (district court weighing similarly situated analysis and exemptions)
- Spinden v. GS Roofing Prods. Co., Inc., 94 F.3d 421 (8th Cir. 1996) (exemption analysis standards; burden on employer to prove exemption)
- Smith v. Heartland Auto. Servs. Inc., 404 F.Supp.2d 1144 (D.Minn. 2005) (job descriptions not controlling for FLSA analysis)
- Turner v. Human Genome Science, Inc., 292 F.Supp.2d 738 (D.Md. 2003) (advisors/consultants to clients may be exempt)
- Dymond v. U.S. Postal Serv., 670 F.2d 93 (8th Cir. 1982) (discretion and judgment in exemption analysis)