Robbie Evans v. Professional Transportation, 614 F. App'x 297

Evans (branch manager) and Booth (assistant manager) worked at PTI’s Chattanooga branch; both opted into the Matthews overtime collective action on March 1, 2012 but did not inform supervisors.
PTI had earlier faced Miller litigation that led to company-wide scheduling changes; management was generally aware of overtime suits.
In early 2012 PTI management increased oversight of Chattanooga (OTP concerns, ban on taxi use, prohibition on managers driving vans, undercover manager assigned) and there were personnel conflicts and maintenance/scheduling problems.
PTI’s Director of Operations, Michael Morin, received reports (including from an undercover manager) and recommended termination of Evans and Booth on March 30, 2012; they were fired April 2, 2012.
Evans and Booth sued under the FLSA § 215(a)(3) alleging retaliatory discharge for joining Matthews; the district court granted summary judgment for PTI holding plaintiffs failed to show the decisionmaker knew of the protected activity.
On appeal the Sixth Circuit affirmed, finding no genuine issue that Morin (the decisionmaker) knew of plaintiffs’ participation in Matthews and rejecting circumstantial inferences of knowledge or a conspiratorial scheme.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs established prima facie FLSA retaliation (employer knew of protected activity)	Morin and other managers must have known because of company hostility to lawsuits, undercover investigations timed to target them, driving ban (tied to overtime suits), and temporal proximity (32 days)	Plaintiffs cannot show the actual decisionmaker (Morin) knew of their participation; actions cited predated or were unrelated to Matthews and PTI offered non-retaliatory reasons	Court held plaintiffs failed the knowledge element of the prima facie case because no evidence Morin knew of Matthews; summary judgment affirmed

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for circumstantial proof of discrimination/retaliation)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard; view evidence in light most favorable to nonmoving party)
Mulhall v. Ashcroft, 287 F.3d 543 (6th Cir. 2002) (circumstantial evidence must be specific; inference of decisionmaker knowledge requires concrete facts)
Adair v. Charter Cnty. of Wayne, 452 F.3d 482 (6th Cir. 2006) (elements of a prima facie FLSA retaliation claim)
Guyan Int’l, Inc. v. Prof’l Benefits Adm’rs, Inc., 689 F.3d 793 (6th Cir. 2012) (standard of review for summary judgment)
Dixon v. Gonzales, 481 F.3d 324 (6th Cir. 2007) (burden-shifting and plaintiff’s persisting burden of persuasion)