Shawn Meeks v. Pacso County Sheriff
688 F. App'x 714
11th Cir.2017Background
- Shawn Meeks, a Road Patrol Deputy for Pasco County (July 2011–March 2015), was assigned a patrol car but lived >15 miles outside the county, so he was required to store the car at a secured county location.
- Each shift Meeks drove his personal car to the Patrol Division Office, picked up his patrol car, activated its radio/AVL, and drove to his patrol zone; at shift end he returned the patrol car to the office and drove home in his personal car.
- The Sheriff did not pay Meeks for time spent transporting the patrol car between the Patrol Division Office and his patrol zone unless he responded to an emergency en route.
- Meeks sued under the FLSA for unpaid overtime for that transportation time; both parties moved for summary judgment.
- The district court granted summary judgment to Meeks, awarding unpaid overtime and liquidated damages; the Sheriff appealed arguing the transport time was noncompensable and that it had a good-faith defense to liquidated damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether transporting the patrol car between the secured parking location and patrol zone is compensable under the FLSA | Meeks: transport is "integral and indispensable" to patrol duties (principal activity) and thus compensable | Sheriff: such travel is noncompensable under the Portal-to-Portal Act as travel to/from the place of performance or as preliminary/postliminary activity | Transporting the patrol car is compensable because it is an intrinsic element of Meeks’s patrol duties and required to perform them |
| Whether Department of Labor regulations support compensation for pickup/transport of employer-provided tools | Meeks: DOL regs treat travel to pick up tools at a designated place as hours worked | Sheriff: argued travel exclusion applies (no contest on regulation application in lower court) | DOL regulation (29 C.F.R. §785.38) confirms travel to pick up tools is part of the day’s work; supports compensability |
| Whether the Sheriff is entitled to avoid liquidated damages by showing good faith and reasonable grounds | Meeks: liquidated damages appropriate; Sheriff acted without good faith and had notice/issues that should have prompted compliance | Sheriff: acted in good faith and reasonably believed its practice complied with FLSA | Sheriff failed to show both objective and subjective good faith; evidence showed awareness of DOL investigation and appellate decisions questioning the practice, so liquidated damages stand |
| Whether summary judgment for Meeks and denial of Sheriff’s cross-motion were appropriate | Meeks: no genuine issue of material fact; entitled to judgment as a matter of law | Sheriff: disputed legal characterization of compensable time and asserted factual defenses | Court affirmed summary judgment for Meeks and denial of Sheriff’s motion; no genuine factual dispute on FLSA violation or on good-faith defense |
Key Cases Cited
- Integrity Staffing Solutions, Inc. v. Busk, 574 U.S. 27 (2014) (defines “principal activity” as activities that are integral and indispensable to primary duties)
- Quigg v. Thomas County Sch. Dist., 814 F.3d 1227 (11th Cir. 2016) (standard of review for summary judgment; evidence construed in favor of nonmoving party)
- Spires v. Ben Hill County, 980 F.2d 683 (11th Cir. 1993) (liquidated damages mandatory absent employer’s showing of good faith)
- Rodriguez v. Farm Stores Grocery, Inc., 518 F.3d 1259 (11th Cir. 2008) (good-faith defense requires objective and subjective proof)
- Joiner v. City of Macon, 814 F.2d 1537 (11th Cir. 1987) (employer who knew or had reason to know FLSA applied cannot establish good faith)