HAVERKAMP v. STAR OF AMERICA, LLC
4:16-cv-00004
S.D. Ind.Jun 16, 2017Background
- Haverkamp and Blair sue Star of America, LLC for unpaid overtime under the FLSA as a putative collective action.
- Star asserts the Motor Carrier Act exemption (29 U.S.C. § 213(b)(1)) applies to its shuttle drivers, negating overtime entitlement.
- Star operates shuttle services between Purdue/ Bloomington and Indianapolis Airport, with a set schedule and routes seven days a week.
- Plaintiffs’ travel is largely intrastate, but there is debate whether it forms part of a continuous interstate transportation stream.
- Evidence shows many passengers have out-of-state billing addresses, yet some passengers do not board planes after shuttle drop-offs, creating material factual disputes over interstate commerce.
- Court applies the two-part MCA exemption test and finds a material issue of fact as to whether Plaintiffs’ duties occurred in interstate commerce, denying summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MCA exemption applies to the shuttle drivers. | Haverkamp/Blair argue continuous interstate movement. | Star argues shuttle is part of interstate stream. | Material issue of fact; summary judgment denied. |
Key Cases Cited
- United States v. Capital Transit Co., 338 U.S. 286 (1949) (interstate transit integral to interstate movement)
- Walters v. American Coach Lines of Miami, Inc., 575 F.3d 1221 (11th Cir. 2009) (common arrangement; airport transfers as interstate travel component)
- Abel v. Southern Shuttle Servs., Inc., 631 F.3d 1211 (11th Cir. 2011) (internet-packages; MCA exemption applies with core shuttle activity)
- Chao v. First Class Coach Co., Inc., 214 F. Supp. 2d 1263 (M.D. Fla. 2001) (interstate continuity of travel for MCA purposes)
- Walling v. Jacksonville Paper Co., 317 U.S. 564 (1943) (intrastate travel as part of interstate commerce)