Laura Canaday v. The Anthem Companies, Inc.
9 F.4th 392
| 6th Cir. | 2021

Background

  • Anthem, headquartered in Indiana, classifies its utilization-review nurses as exempt from FLSA overtime; Laura Canaday (a Tennessee nurse) sued under the FLSA as the named plaintiff in a collective action.
  • Dozens of nurses from multiple states filed written consents to opt into Canaday’s collective; some were Tennessee-based, others were out-of-state.
  • Anthem moved to dismiss the out-of-state opt-in plaintiffs for lack of personal jurisdiction; the district court dismissed those nonresident plaintiffs without prejudice and certified the order for interlocutory appeal.
  • The Sixth Circuit (majority opinion by Chief Judge Sutton) affirmed dismissal of the out-of-state plaintiffs, holding that specific personal jurisdiction requires a claim-specific nexus between the forum and each plaintiff’s claim (applying Bristol-Myers principles to FLSA collectives under Rule 4(k)).
  • The court rejected arguments that the FLSA or Rule 4(k) allows nationwide service for collectives, that opt-in notices alone cure jurisdictional limits, and that pendent or class-action personal-jurisdiction doctrines apply.
  • Judge Donald dissented, arguing Bristol-Myers does not control federal FLSA collectives, that the suit-level analysis supports jurisdiction over the entire collective, and that dismissing out-of-state opt-ins undermines FLSA efficiency and uniformity.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether a federal court can exercise specific personal jurisdiction over an employer for out-of-state opt-in plaintiffs in an FLSA collective without a forum-specific connection Canaday: federal forum + FLSA claims suffice; only need contacts with the U.S. generally; named plaintiff’s service should support the whole suit Anthem: Bristol-Myers and Rule 4(k) require a claim-specific connection to the forum for each opt-in plaintiff Held: No—specific jurisdiction requires a claim-specific link between each nonresident plaintiff’s claim and the forum (applying Bristol-Myers under Rule 4(k))
Whether the FLSA or Rule 4(k) authorizes nationwide service of process for collective actions Canaday: Congress could have intended nationwide reach for federal FLSA claims Anthem: FLSA contains no nationwide-service provision; Rule 4(k) ties federal service to state long-arm reach Held: FLSA contains no nationwide service; Rule 4(k)(1)(A) limits federal courts to the forum state’s jurisdictional reach
Whether opt-in notices (Rule 5) or the named plaintiff’s service cure personal jurisdiction defects for additional opt-ins Canaday: once defendant appears and opt-ins serve notices, no further service/personal-jurisdiction showing is needed for opt-ins Anthem: Opt-ins are new party plaintiffs; Rule 4(k) and due process still constrain jurisdiction for each claim Held: Opt-in notices do not override Rule 4(k); jurisdictional limits remain and require a forum connection for each claim
Whether pendent personal jurisdiction or analogies to Rule 23 class actions permit jurisdiction over out-of-state opt-ins Canaday: collective actions resemble single representative suits; Lyngaas (class action line) shows Bristol-Myers exception; pendent jurisdiction should apply Anthem: Collective actions are opt-in and individual in nature; pendent doctrines and class-action rules do not apply Held: Court rejects pendent personal-jurisdiction and class-action analogies; distinguishes class actions and declines to extend Lyngaas exception to FLSA collectives

Key Cases Cited

  • Int’l Shoe Co. v. Washington, 326 U.S. 310 (establishes minimum-contacts standard for specific jurisdiction)
  • Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (requires claim-specific connection between forum and each plaintiff for specific jurisdiction)
  • Daimler AG v. Bauman, 571 U.S. 117 (limits general jurisdiction to where a corporation is "at home")
  • Omni Capital Int’l v. Rudolf Wolff & Co., 484 U.S. 97 (service of process is prerequisite to personal jurisdiction; Congress knows how to authorize nationwide service)
  • Hoffmann-La Roche Inc. v. Sperling, 493 U.S. 165 (describes the FLSA opt-in/collective mechanism and district court management authority)
  • Walden v. Fiore, 571 U.S. 277 (specific jurisdiction focuses on relationship among defendant, forum, and litigation)
  • Burger King Corp. v. Rudzewicz, 471 U.S. 462 (forum contacts must not be random, fortuitous, or attenuated)
  • J. McIntyre Mach., Ltd. v. Nicastro, 564 U.S. 873 (distinguishes federal and state sovereignty in personal jurisdiction contexts)
  • Burnham v. Superior Ct., 495 U.S. 604 (historical discussion of service and jurisdiction)
  • Murphy Bros. v. Michetti Pipe Stringing, Inc., 526 U.S. 344 (service of process substitutes for older writs and is central to commencement of suit)
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