Donna Craig v. Bridges Bros. Trucking LLC, 823 F.3d 382

Donna Craig was a bookkeeper for Bridges Brothers Trucking from Oct 2010 to 2012 and recorded roughly 500 overtime hours over her employment, usually paid only at straight time except one hour later paid at time-and-a-half.
Craig prepared and submitted weekly timesheets (including her own), task descriptions, and a payroll summary to owner Michael Bridges for approval; payroll was not processed until his approval.
Bridges testified he reviewed only the payroll summary and did not examine time sheets in detail; he also instructed Craig to itemize tasks so he could “keep track of her time.”
Evidence suggesting employer awareness includes Craig’s testimony she told Bridges she took work home, an email from Bridges’s son noting Craig’s weekend work and urging a 40‑hour cap for June, and supervisory weekend visits by Mr. Bridges.
Craig sued under the FLSA and analogous Ohio laws for unpaid overtime; the district court granted defendant’s summary judgment and denied Craig’s cross-motion; the Sixth Circuit reversed defendant’s SJ and affirmed denial of plaintiff’s SJ, remanding for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Craig waived FLSA rights by miscalculating/pay‑reporting overtime	Craig says she did not waive rights; FLSA rights are nonwaivable	Bridges argued Craig misreported time and thus thwarted employer’s ability to comply	Court: No waiver; employee cannot waive FLSA rights — reversal of district court on this point
Standard for employer constructive knowledge of overtime	Craig: employer should be charged if it could have learned from its own records	Bridges: lacked actual/constructive knowledge because employee failed to report properly	Court: Adopts "reasonable diligence" constructive‑knowledge standard (employer should have discovered by reasonable diligence)
Whether Bridges had constructive/actual knowledge here (factual)	Craig: evidence (timesheets, telling Bridges, son’s email, weekend supervision) creates triable issue	Bridges: relied on summary reports and claimed no detailed review of time cards	Held: Material factual disputes exist; summary judgment for defendant inappropriate — remand for trial
Whether plaintiff was entitled to summary judgment based on timesheets alone	Craig: employer’s records show uncompensated overtime, so SJ as a matter of law	Bridges: knowledge is a separate factual question; access to records does not automatically establish constructive knowledge	Held: Denial of Craig’s cross‑motion affirmed — knowledge is a jury question, not resolved as matter of law

Barrentine v. Arkansas-Best Freight Sys., Inc., 450 U.S. 728 (FLSA overtime rights are nonwaivable)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standards; inferences and credibility for jury)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (view evidence in light most favorable to nonmovant on summary judgment)
White v. Baptist Mem'l Health Care Corp., 699 F.3d 869 (6th Cir. 2012) (employer not liable if reasonable reporting process exists and employee fails to follow it; exceptions where employer prevents reporting or is otherwise notified)
Reich v. Stewart, 121 F.3d 400 (8th Cir. 1997) (actual and constructive knowledge can establish employer liability for overtime)
Carlisle Equip. Co. v. U.S. Sec'y of Labor, 24 F.3d 790 (6th Cir. 1994) (constructive knowledge = discoverable by reasonable diligence)
Taft Broadcasting Co. v. United States, 929 F.2d 240 (6th Cir. 1991) (cross‑motions for summary judgment require separate evaluation)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (employee may rely on employer records to prove uncompensated overtime)