Garcia v. Tyson Foods, Inc., 770 F.3d 1300

Tyson Foods employed plaintiffs at a Finney County, Kansas facility; employees wore protective gear and had to don/doff before and after shifts.
Two pay systems existed: gang-time (production-pay) and K-Code (pre/post-shift activities).
K-Code initially 4 minutes (knife departments only), later expanded to up to 7 minutes, then increased further in 2010 to all hourly workers (20–22 minutes per shift).
Jury found underpayment for pre/post-shift activities under FLSA and Kansas Wage Protection Act; district court certified class/collective actions and awarded substantial attorneys’ fees.
District court denied Tyson’s motion for judgment as a matter of law; Tyson appealed on liability and fee issues; appellate court affirmed both.
Damages were calculated using Tyson's internal hours vs. actual time spent; substantial evidence supported class-wide liability; fees awarded were reviewed for reasonableness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence to support class-wide liability	Garcia asserted underpayment across the class supported by trial evidence	Tyson argued no class-wide underpayment proved	Yes, evidence supported class-wide liability
Whether damages for the class were properly calculated	Plaintiffs showed substantial uncompensated time per shift	Defendant challenged per-class calculations	Damages within the range of evidence; class-wide liability supported
Whether the district court properly allowed recovery of fees for related state and unsuccessful federal claims	Fees related to interrelated claims should be recoverable	Fees should be limited to successful federal claims	Yes, fees for related claims were recoverable
Whether the district court abused its discretion in denying production of itemized time records	Itemized records needed to verify billing	Court could review in camera and use summaries	No abuse; district court acted within discretion
Whether the fee award was excessive relative to damages	Full fee recovery warranted by substantial success	Fee should be proportionally reduced	No abuse of discretion; fee award upheld

Sanjuan v. IBP, Inc., 275 F.3d 1290 (10th Cir. 2002) (standard for sufficiency review in wage cases)
Baty v. Willamette Indus., Inc., 172 F.3d 1232 (10th Cir. 1999) (evidence in discrimination/class actions; inference allowed)
First Alliance Mortg. Co. v. Lehman Commercial Paper, Inc., 471 F.3d 977 (9th Cir. 2006) (class action evidence standard post-certification)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (U.S. 1946) (plaintiffs need not prove precise extent of uncompensated work when records are inadequate)
Perez v. Mountaire Farms, Inc., 650 F.3d 350 (4th Cir. 2011) (use of time-study averages when employer records insufficient)
Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541 (U.S. 2011) (class certification standards (relevant but not controlling here))
Thiessen v. Gen. Elec. Corp., 267 F.3d 1095 (10th Cir. 2001) (class action standards; related claims analysis)
Espenscheid v. DirectSat USA, LLC, 705 F.3d 770 (7th Cir. 2013) (class action/fee issues in related context)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (fee-shifting and extent of successful claims; discretion of district court)
Riverside v. Rivera, 477 U.S. 561 (1986) (fee awards under § 1988; discretion where full proportionality not required)
Hampton v. Dillard Dep’t Stores, Inc., 247 F.3d 1091 (10th Cir. 2001) (claims relatedness for fee recovery; interrelated nature of lawsuit)