Linda Ash v. Anderson Merchandisers, LLC, 799 F.3d 957

Plaintiffs Linda Ash and Abbie Jewsome sued Anderson Merchandisers, West AM, and AnConnect under the FLSA for unpaid overtime, filing on April 21, 2014 on behalf of themselves and similarly situated persons.
Defendants moved to dismiss; the district court granted the motion and entered judgment for defendants on July 9, 2014.
Plaintiffs moved to vacate under Rules 59(e) and 60(b) and sought leave to file a First Amended Complaint nine days after the dismissal; the district court denied the motion and the request to amend.
The district court dismissed the complaint for two independent reasons: (1) plaintiffs failed to plausibly allege that the defendant entities were their employers under the FLSA (pleaded only conclusory integrated-enterprise language), and (2) plaintiffs failed to plead a substantive overtime claim (court did not resolve the circuit-wide standard question because of employer deficiency).
The Eighth Circuit reviewed de novo the Rule 12(b)(6) dismissal and for abuse of discretion the denial of post-judgment leave to amend, and affirmed both rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint plausibly alleged employer relationship under FLSA	Ash/Jewsome: allegation that defendants were an "integrated enterprise" sufficed at pleading stage; discovery needed to establish corporate details	Defendants: plaintiffs’ allegations were conclusory and failed to plead the economic-reality employment factors	Court: Dismissal affirmed — conclusory integrated-enterprise allegations (labels/conclusions) insufficient; plaintiffs needed factual allegations about economic reality (control, hiring/firing, pay source, supervisors)
Whether district court abused discretion by denying post-judgment leave to amend	Ash/Jewsome: denial prevented adjudication on the merits; they sought leave promptly after dismissal	Defendants: plaintiffs unduly delayed and could have sought leave before ruling; denial was within court's discretion	Court: Affirmed — denial not an abuse of discretion given plaintiffs’ delay (they waited until after dismissal and judgment despite notice via motion to dismiss)

Horras v. Am. Capital Strategies, Ltd., 729 F.3d 798 (8th Cir.) (standard for Rule 12(b)(6) review and abuse-of-discretion review of leave to amend)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (labels-and-conclusions insufficient under Rule 8)
Tony & Susan Alamo Found. v. Sec’y of Labor, 471 U.S. 290 (FLSA employment test: economic reality)
Goldberg v. Whitaker House Coop., Inc., 366 U.S. 28 (factors relevant to employee-employer relationship)
Foman v. Davis, 371 U.S. 178 (factors guiding leave-to-amend discretion)