Martin v. Spring Break '83 Productions, L.L.C.
688 F.3d 247
| 5th Cir. | 2012Background
- Appellants J. T. Martin, J. R. Martin, Keyes, and Boger worked as grips for Spring Break Louisiana on Spring Break ‘83 (Oct–Dec 2007).
- They were union members (Local 478) and covered by a Collective Bargaining Agreement recognizing the Union as exclusive representative.
- A grievance over unpaid wages led to a Settlement Agreement between the Union and Spring Break Louisiana (signed Nov 3, 2009).
- Plaintiffs filed suit in California (June 16, 2009); case was removed to federal court and transferred to the Eastern District of Louisiana.
- The district court granted summary judgment on the FLSA claims (June 24, 2011).
- Appellants contest both employer status of some individuals and the release effect of the Settlement Agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Callahan, Bours, Hermansen, Chortkoff FLSA employers? | Martin Declaration shows Callahan had hiring/ firing power and control. | Record shows no independent control; supervision and pay handled by others; no records maintained by them. | None of the four were FLSA employers. |
| Does the Settlement Agreement bar further FLSA claims against Spring Break Louisiana? | Release is unenforceable since not signed by Appellants and may impermissibly waive rights. | Settlement bound IATSE employees; bona fide dispute over hours resolved by payment; release enforceable. | Settlement Agreement enforceable; releases bona fide-dispute claims against Spring Break Louisiana. |
Key Cases Cited
- Gray v. Powers, 673 F.3d 352 (5th Cir. 2012) (economic reality test factors guide who is an employer)
- Goldberg v. Whitaker House Co-op, Inc., 366 U.S. 28 (Supreme Court 1961) (employer status under FLSA context)
- Williams v. Henagan, 595 F.3d 610 (5th Cir. 2010) (economic reality test application)
- Martinez v. Bohls Bearing Equip. Co., 361 F. Supp. 2d 608 (W.D. Tex. 2005) (private settlement permissible under bona fide dispute)
- Brooklyn Sav. Bank v. O’Neil, 324 U.S. 697 (Supreme Court 1945) (precludes waivers outside bona fide settlements context)
- Barrentine v. Arkansas-Best Freight Sys., 450 U.S. 728 (Supreme Court 1981) (FLSA rights nonwaivable; settlement context analyzed)
- Thomas v. Louisiana, 534 F.2d 613 (5th Cir. 1976) (private FLSA settlement upheld when rights preserved)
- Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (DOL/court approved settlements differ; context-specific)
- Taylor v. Progress Energy, Inc., 415 F.3d 364 (4th Cir. 2005) (FMLA-specific; distinction from FLSA in discussion)