Hood v. Capstone Logistics, LLC
3:22-cv-00292-RJC-SCR
| W.D.N.C. | Aug 22, 2023Background
- Plaintiff Tyler Hood, a former Capstone Logistics employee, alleges Capstone failed to pay minimum wage and overtime and seeks an FLSA collective action (nationwide) and a North Carolina Wage and Hour Act class (North Carolina only).
- Capstone moved to dismiss or strike the nationwide collective claims, arguing under Bristol-Myers that the court lacks personal jurisdiction over out-of-state collective members.
- The Magistrate Judge recommended granting Capstone’s motion, relying on several circuit decisions applying Bristol-Myers to opt-in collective claims.
- No putative collective members have opted in at this stage, so no out-of-state claims are yet before the court.
- The district court concluded the motion was premature: ruling now on jurisdiction over hypothetical out-of-state opt-ins would be an advisory opinion and violate Article III.
- The court did not adopt the M&R and denied Capstone’s motion to dismiss or strike; it will address jurisdiction over out-of-state opt-ins if and when they are actually asserted.
Issues
| Issue | Hood's Argument | Capstone's Argument | Held |
|---|---|---|---|
| Whether Bristol-Myers prevents the court from exercising personal jurisdiction over out-of-state FLSA opt-in plaintiffs | Bristol-Myers does not bar collective claims here and, in any event, resolving jurisdiction now is premature | Bristol-Myers requires dismissal/striking of out-of-state collective claims for lack of personal jurisdiction | Court declined to decide now—motion denied as premature; jurisdictional question reserved for if/when opt-ins appear |
| Whether Capstone’s motion is ripe or would produce an advisory opinion | Motion is unripe because no opt-ins exist and no live controversy over out-of-state claims | Court should resolve jurisdiction now for efficiency and case management | Court agreed with Hood: deciding jurisdiction over hypothetical opt-ins would be advisory and constitutionally improper; motion denied |
Key Cases Cited
- Bristol-Myers Squibb Co. v. Superior Court of California, 582 U.S. 255 (2017) (limits on state-court personal jurisdiction over nonresident plaintiffs)
- Fischer v. Fed. Express Corp., 42 F.4th 366 (3d Cir. 2022) (applied Bristol-Myers to FLSA collective claims)
- Canaday v. Anthem Cos., 9 F.4th 392 (6th Cir. 2021) (applied Bristol-Myers to out-of-state opt-ins)
- Vallone v. CJS Sols. Grp., LLC, 9 F.4th 861 (8th Cir. 2021) (applied Bristol-Myers to collective action opt-ins)
- Waters v. Day & Zimmerman NPS Inc., 23 F.4th 84 (1st Cir. 2022) (took a different view on Bristol-Myers in the collective context)
- Carney v. Adams, 141 S. Ct. 493 (2020) (Article III case-or-controversy principle)
- Immigration & Naturalization Serv. v. Chadha, 462 U.S. 919 (1983) (federal action must conform to constitutional procedures)
- Golden v. Zwickler, 394 U.S. 103 (1969) (federal courts do not issue advisory opinions)