Lori Chavez-DeRemer v. Alpha & Omega USA, Inc., 23-3170

Alpha & Omega USA, Inc. d/b/a Travelon Transportation, provides non-emergency transportation in the Minneapolis-St. Paul area and hired drivers whose employment status (employee vs. independent contractor) was disputed.
The Secretary of Labor sued Travelon, alleging violations of the Fair Labor Standards Act (FLSA) for failure to pay minimum wage, overtime, and inadequate record-keeping.
Initially, the district court granted summary judgment in favor of the Secretary, classifying drivers as employees and awarding $254,628.20 in back wages and liquidated damages.
The Eighth Circuit reversed and remanded for trial, citing unresolved material factual disputes regarding the employment relationship under the "economic realities" test.
After a limited trial focusing on specific economic realities test factors, the jury found for the Secretary, and the district court imposed the same damages as before.
Travelon appealed, challenging the trial's scope, jury instructions, damages calculations, and denial of various post-trial motions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Limitation of trial scope	Only disputed factors under the economic realities test should go to the jury	Jury should decide all economic realities factors and related liability	District court properly limited scope to disputed factors per mandate
Sufficiency of evidence for jury verdict	Substantial evidence supported jury's findings on disputed factors	Insufficient evidence supported verdict; verdict against weight of evidence	Ample evidence supported verdict; district court properly denied Rule 50(b)/new trial
Jury instructions on control factor	Proper instruction focused only on degree of control, not reasons for control	Instructions should address why company exerted control	Instructions were not legally incorrect; no probable effect on verdict
Opportunity to contest liquidated damages	State findings irrelevant; summary judgment already addressed suitability	Should have been allowed to present additional evidence on good faith	No miscarriage of justice; summary judgment record sufficient to address issue

Walsh v. Alpha & Omega USA, Inc., 39 F.4th 1078 (8th Cir. 2022) (initial appeal identifying genuine disputes of fact under FLSA employment relationship)
United States v. Castellanos, 608 F.3d 1010 (8th Cir. 2010) (law of the case and mandate rule on remand)
In re Tri-State Fin., LLC, 885 F.3d 528 (8th Cir. 2018) (scope of appellate mandate and district court discretion)
Lincoln Composites, Inc. v. Firetrace USA, LLC, 825 F.3d 453 (8th Cir. 2016) (standard for reviewing jury instructions)