Jose Ageo Luna Vanegas v. Signet Builders, Inc., 113 F.4th 718

Background

Jose Ageo Luna Vanegas, a Texas-based guestworker hired by Signet Builders, filed a Fair Labor Standards Act (FLSA) suit alleging he and other workers were denied overtime pay, pursuing a collective action (opt-in group suit under FLSA).
Signet Builders is incorporated and headquartered in Texas but does business nationwide, largely employing H-2A visa workers for agricultural work including in Wisconsin.
The legal focus is on whether out-of-state workers can participate in a Wisconsin federal court FLSA collective action if they have no work-related contacts with Wisconsin.
After initial dismissal (on different grounds), the district court allowed nationwide notice to potential opt-in plaintiffs, but certified for appeal the issue of whether specific personal jurisdiction is needed over each opt-in plaintiff's claims.
The Seventh Circuit accepted interlocutory appeal to resolve if federal courts can adjudicate FLSA collective actions for out-of-state opt-in plaintiffs when only specific (but not general) jurisdiction exists over the defendant.

Issues

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Must a federal court have personal jurisdiction over each opt-in plaintiff's claim in FLSA collectives?	No, jurisdiction over just the representative plaintiff suffices, similar to Rule 23 class actions.	Yes, the court must have specific jurisdiction over each opt-in’s claim individually; otherwise, jurisdiction is improper.	Yes, court must have personal jurisdiction over each opt-in’s claim; BMS applies to FLSA collectives as to mass actions.
Does Fed. R. Civ. P. 4 permit nationwide personal jurisdiction in FLSA collective actions without state-specific contacts?	Yes, after initial establishment in representative’s forum, later opt-ins are governed only by Fifth Amendment due process.	No, since FLSA lacks a statute authorizing nationwide service, Rule 4 incorporates state law limits on jurisdiction (here, Wisconsin).	No; under Rule 4(k)(1)(A), federal courts only have jurisdiction if a state court in the forum state would.
Are FLSA collective actions more like Rule 23 class actions (where only the named plaintiff needs to establish jurisdiction) or mass actions (where each plaintiff does)?	Like class actions—efficient, representative, and should allow jurisdiction via representative only.	Like mass actions—each opt-in plaintiff is a real party in interest and must establish jurisdiction individually.	More akin to mass actions; thus, BMS rule applies, requiring specific jurisdiction over each claim.
Does the FLSA collective action mechanism or legislative history indicate an intent to permit nationwide collectives irrespective of state-specific jurisdiction?	Yes, structure and purpose of FLSA support broad, efficient collective actions for enforcement.	No, history and statutory text show Congress wanted only genuinely interested parties—each must establish jurisdiction.	Statutory text and history support individualized analysis; opt-in plaintiffs are parties and must establish jurisdiction.

Key Cases Cited

Bristol-Myers Squibb Co. v. Superior Ct. of California, 582 U.S. 255 (2017) (personal jurisdiction must exist for each plaintiff’s claim in mass actions; precludes loose nationwide jurisdiction in state courts)
Goodyear Dunlop Tires Ops., S.A. v. Brown, 564 U.S. 915 (2011) (differentiates between general and specific personal jurisdiction)
Daimler AG v. Bauman, 571 U.S. 117 (2014) (reiterates scope of general jurisdiction)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (defines specific vs. general jurisdiction standards)
Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) (representative adequacy and class action procedures)
Genesis Healthcare Corp. v. Symczyk, 569 U.S. 66 (2013) (distinguishes FLSA collective actions from Rule 23 class actions)
Omni Capital Int’l, Ltd. v. Rudolf Wolff & Co., Ltd., 484 U.S. 97 (1987) (personal jurisdiction tied to effective service under Rule 4)