Evelyn Garrison v. ConAgra Foods Packaged Foods
833 F.3d 881
8th Cir.2016Background
- Garrison and ten opt-in employees sued ConAgra Foods Packaged Foods under AMWA and FLSA for alleged unpaid overtime due to improper exempt classification.
- District court granted summary judgment holding plaintiffs were bona fide executives under the FLSA and AMWA and thus not entitled to overtime.
- First three prongs of the executive exemption were undisputed; fourth prong required plaintiffs’ hiring/firing input to be given particular weight.
- Evidence showed plaintiffs’ recommendations affected probationary employees, promotions/demotions, and scheduling; management followed many of these recommendations.
- District court denied ConAgra’s costs under Rule 54(d) due to lack of controlling authority and uncertainty in Arkansas courts; alternative holding would have assessed costs against plaintiffs.
- Court of Appeals affirms summary judgment for ConAgra and vacates denial of costs, remanding for consideration of costs against Garrison and the ten opt-in plaintiffs
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Garrison and opt-ins meet the fourth prong of the executive exemption | Garrison argues input is not given particular weight | ConAgra contends input is given particular weight through monitoring, reassignment, discipline recommendations | Yes; plaintiffs’ input was given particular weight and they are exempt |
| Whether prevailing FLSA defendant may recover costs under Rule 54(d) despite §216(b) | N/A | Prevailing defendant should be able to recover costs; district court erred in denying | Prevailing FLSA defendant not precluded from costs; remanded to determine amount and allocation against plaintiffs |
Key Cases Cited
- Madden v. Lumber One Home Ctr., Inc., 745 F.3d 899 (8th Cir. 2014) (definition of executive exemption and particular weight considerations under §541.100)
- Beauford v. ActionLink, LLC, 781 F.3d 396 (8th Cir. 2015) (summary judgment framework and executive exemption analysis)
- Martin v. DaimlerChrysler Corp., 251 F.3d 691 (8th Cir. 2001) (abstention on costs and prevailing party standards)
- In re Raynor, 617 F.3d 1065 (8th Cir. 2010) (statutory interpretation standard for costs and Rule 54(d))
- Lykken v. Brady, 622 F.3d 925 (8th Cir. 2010) (summary judgment effect and evidence consistency)