SLOANE v. GULF INTERSTATE FIELD SERVICES, INC, 4:16-cv-01571

Plaintiff Sloane (counsel previously brought Hughes v. Gulf Interstate) filed an FLSA collective/class action; case transferred to the Middle District of Pennsylvania and the Court denied class/collective certification on March 24, 2017.
Hughes, a related FLSA matter in the Southern District of Ohio, resulted in summary judgment for defendant and was on appeal to the Sixth Circuit when Sloane sought a stay here.
About one month before the dispositive motions deadline, Sloane moved to stay this action pending the Sixth Circuit’s decision in Hughes.
The Court assessed whether a stay was warranted given differing facts and legal issues between Hughes and Sloane (different plaintiffs, sites, exemptions, discovery posture, and applicable circuit law).
The Court found Hughes would at best be instructive and would not retroactively change the extensive discovery already conducted in Sloane or alter the Court’s certification analysis.
The Court concluded a stay would prejudice Defendant by halting progress near the dispositive-motion deadline and denied the motion to stay, keeping existing case-management deadlines in effect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to stay Sloane pending the Hughes appeal	Stay pending Sixth Circuit would likely affect certification and thus conserve resources	Hughes differs materially and will not control Sloane; staying would prejudice defendant and delay proceedings	Denied — stay not warranted
Whether Hughes’ outcome would simplify or alter the Court’s certification decision	Hughes could validate an Ohio subclass and impact certification here	Hughes involves different law, facts, exemptions, and would not retroactively change discovery or this Court’s analysis	Denied — Hughes would be at best instructive and not dispositive
Whether a stay would promote judicial economy versus cause prejudice	A stay could conserve resources if Hughes resolves central legal issues	A stay would stonewall progress near dispositive-motion deadline and unfairly prejudice defendant	Denied — prejudice to defendant and limited benefit to judicial economy

CTF Hotel Holdings, Inc. v. Marriott Intern., Inc., 381 F.3d 131 (3d Cir. 2004) (stay is an extraordinary measure; party seeking stay must show compelling reasons)
Cost Bros. v. Travelers Indem. Co., 760 F.2d 58 (3d Cir. 1985) (district court has discretion to stay as part of control over its docket and conserving judicial resources)
Toshiba Samsung Storage Tech. Korea Corp. v. LG Elecs., Inc., 193 F. Supp. 3d 345 (D. Del. 2016) (factors for stays include simplifying issues, litigation status, and prejudice to nonmovant)