Jeffrey Moran v. Al Basit LLC
788 F.3d 201
| 6th Cir. | 2015Background
- Plaintiff Jeffrey Moran worked as a mechanic at Defendants’ Warren, MI Auto Pro shop from mid‑2011 to April 30, 2013 and alleges regular overtime (avg. 65–68 hrs/week).
- Moran says he was paid $300/week plus occasional bonuses, required to start early and stay until repairs were finished; he received no overtime pay and left after a pay/overtime dispute.
- Defendants maintain Moran was hired for 30 hours/week at $300 and produced paystubs and handwritten timesheets showing ~30 hours/week for most weeks.
- Defendants rely on security‑camera checks and an affidavit from a manager (John Blue) denying overtime work; Moran contests the accuracy of the timesheets.
- District court granted summary judgment for Defendants on Moran’s FLSA overtime and retaliatory‑discharge claims; Moran appealed only the overtime claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff’s testimony alone can create a genuine dispute of material fact about hours worked under the FLSA | Moran testified to a consistent long schedule (start/end times and weekly hours), which should suffice to survive summary judgment | Timesheets and paystubs are contemporaneous objective records showing Moran worked ~30 hrs/week; no corroborating evidence for Moran’s overtime claim | Court held Moran’s testimony, though imprecise, is sufficient to create a genuine issue of material fact and defeat summary judgment |
Key Cases Cited
- Mutchler v. Dunlap Mem’l Hosp., 485 F.3d 854 (6th Cir. 2007) (standard of review for summary judgment)
- Little Caesar Enters., Inc. v. OPPCO, LLC, 219 F.3d 547 (6th Cir. 2000) (inferences favor nonmoving party on summary judgment)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (trial court must not weigh evidence or make credibility determinations at summary judgment)
- Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (U.S. 1946) (employee burden and employer recordkeeping duty under FLSA)
- O’Brien v. Ed Donnelly Enters., Inc., 575 F.3d 567 (6th Cir. 2009) (plaintiff testimony can create genuine issue on off‑the‑clock FLSA claims)
- Harris v. J.B. Robinson Jewelers, 627 F.3d 235 (6th Cir. 2010) (plaintiff’s testimony alone may create a jury question)
- Schreiber v. Moe, 596 F.3d 323 (6th Cir. 2010) (credibility determinations inappropriate at summary judgment)