Samuel Calderon v. GEICO General Insurance Co, 754 F.3d 201

Plaintiffs are former and current GEICO claims Investigators who sued as a class alleging GEICO misclassified them as exempt from the FLSA and New York law overtime protections.
The district court granted plaintiffs’ motion and denied GEICO’s on liability, holding the Investigators were not covered by the FLSA administrative exemption (see Calderon v. GEICO Gen. Ins. Co.).
On remedies, the district court ruled GEICO acted in good faith (no willfulness), limited the statute of limitations to two years, denied liquidated damages and prejudgment interest, and adopted the Missel fixed-salary overtime computation method.
The court entered a “Stipulated Order Relating to Remedy” setting a formula for backpay calculations but left factual application of the formula to be performed by a mutually acceptable entity, with counsel review, and retained jurisdiction to resolve disputes about the remedy.
Both sides reserved appeal rights; GEICO appealed liability and plaintiffs cross-appealed remedy rulings. The Fourth Circuit examined whether it had jurisdiction to hear these appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Liability: whether Investigators fall within FLSA administrative exemption	Investigators performed duties meeting exemption criteria	Investigators performed routine investigative tasks not qualifying for the administrative exemption	District court found Investigators not exempt; that liability ruling is not final for appellate review here
Willfulness / Statute of limitations (remedy)	Plaintiffs argued willful violation -> 3-year limitation	GEICO argued good-faith defense -> 2-year limitation	District court found GEICO acted in good faith and limited claims to two years; appellate review dismissed for lack of finality
Liquidated damages & prejudgment interest	Plaintiffs sought liquidated damages and interest	GEICO argued those were unavailable given good-faith defense	District court denied liquidated damages and prejudgment interest; appellate review dismissed for lack of finality
Finality / Appealability of remedy order	Plaintiffs contended remedy order was final judgment permitting immediate appeal	GEICO contended underlying liability order could be appealed now	Fourth Circuit held the remedy order was not a final money judgment (facts needed to compute damages remain unresolved), so appeals dismissed for lack of jurisdiction; §1292(b) certification was not sought

Calderon v. GEICO Gen. Ins. Co., 917 F. Supp. 2d 428 (D. Md. 2012) (district-court liability ruling at issue)
Ray Haluch Gravel Co. v. Cent. Pension Fund, 134 S. Ct. 773 (2014) (definition of final decision for §1291 purposes)
United States v. F. & M. Schaefer Brewing Co., 356 U.S. 227 (1958) (when an opinion embodies an enforceable money judgment)
Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (1949) (purpose of final-judgment rule)
Carolina Power & Light Co. v. Dynegy Mktg. & Trade, 415 F.3d 354 (4th Cir. 2005) (liability judgment that does not fix damages is not final)
Ram v. Paramount Film Distrib. Corp., 278 F.2d 191 (4th Cir. 1960) (distinguished; finality where all facts to compute recovery were determined)
Republic Nat. Gas Co. v. Oklahoma, 334 U.S. 62 (1948) (ministerial calculations vs. judgments requiring further judicial exercise)
Buchanan v. United States, 82 F.3d 706 (7th Cir. 1996) (judgment not final when amount or formula to compute money is unspecified)
Associated Stores, Inc. v. Indus. Loan & Inv. Co., 313 F.2d 134 (4th Cir. 1963) (no final judgment where damages depend on facts not yet determined)
Pemberton v. State Farm Mut. Auto. Ins. Co., 996 F.2d 789 (5th Cir. 1993) (appealability of liability determinations that do not fix damages; §1292(b) route)
Liberty Mut. Ins. Co. v. Wetzel, 424 U.S. 737 (1976) (Rule 54(b) limited to judgments disposing of claims)