Joyce Vallone v. CJS Solutions Group, LLC, 9 F.4th 861

HCI Solutions Group (Florida) hires consultants on a per-project basis to provide on-site training at "go live" events; HCI arranges or reimburses travel but does not pay consultants for travel time.
Plaintiffs Joyce Vallone (New York) and Erasmus Ikogor (Florida) traveled to Mayo Clinic projects in Rochester, Minnesota; they completed pre-travel paperwork but performed no HCI work while in transit and received no travel pay.
Plaintiffs sued under the Fair Labor Standards Act (FLSA) seeking pay for out-of-town travel and moved to certify a nationwide collective action.
The district court conditionally certified a collective action limited to travel claims tied to Minnesota (and to Minnesota residents) for lack of personal jurisdiction over unrelated claims.
On summary judgment the court held plaintiffs were not HCI employees while traveling (duties began when the project commenced and ended when they were cut), so travel time was not compensable; the panel affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did HCI waive a personal-jurisdiction defense by its answer?	HCI's answer was ambiguous and failed to raise the defense.	HCI's answer referenced due-process limits and later briefed jurisdiction; no waiver.	No waiver; reference to due process plus briefing gave adequate notice.
Could Minnesota jurisdiction over some travel claims support nationwide travel claims in a collective action?	Jurisdiction over Minnesota travel claims permits adjudication of all travel claims.	Each unpaid-wage claim is distinct; no connection to Minnesota = no specific jurisdiction.	Rejected plaintiff; jurisdiction must be claim-specific; non-MN claims excluded.
Is travel time to/from a project compensable because consultants were "employees" while traveling?	Travel is primarily for HCI's benefit, so plaintiffs were employed during travel.	Travel produced no immediate benefit to HCI and plaintiffs did no work in transit; thus not employment.	Travel not compensable; plaintiffs were not employees while traveling.
Did signing contingent offer letters make plaintiffs employees before project start?	Signatures on contingent at-will offers established employment pre-travel.	Offers were not employment contracts and contemplated no work until project start.	No; contingent offers alone did not create employment before work began.

Ins. Corp. of Ir. v. Compagnie des Bauxites de Guinee, 456 U.S. 694 (Due process limits on personal jurisdiction)
Goodyear Dunlop Tires Ops., S.A. v. Brown, 564 U.S. 915 (corporate minimum-contacts principle)
Bristol-Myers Squibb Co. v. Superior Ct. of Cal., 137 S. Ct. 1773 (specific jurisdiction requires connection between forum and claim)
Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (claims must arise out of or relate to defendant’s forum contacts)
Keeton v. Hustler Magazine, Inc., 465 U.S. 770 (nationwide-damages discussion distinguished)
Tony & Susan Alamo Found. v. Sec'y of Labor, 471 U.S. 290 (economic-reality test; no immediate advantage = no employment)
Walling v. Portland Terminal Co., 330 U.S. 148 (definition of "employ"/"work")
Reich v. ConAgra, Inc., 987 F.2d 1357 (employer benefit alone may not establish employment)
Dellinger v. Sci. Applications Int'l Corp., 649 F.3d 226 (contingent offer acceptance does not establish employment before work)
Petroski v. H & R Block Enters., LLC, 750 F.3d 976 (employee status and travel-time analysis)
Wisland v. Admiral Beverage Corp., 119 F.3d 733 (Rule 12 waiver requires clear short-and-plain terms)