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Stainbrook v. Minnesota Department of Public Safety
239 F. Supp. 3d 1123
D. Minnesota
2017
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Background

  • Plaintiff Quint Stainbrook, a Minnesota State Patrol field lieutenant, sued the Minnesota Department of Public Safety under the FLSA claiming unpaid overtime for work over 40 hours/week.
  • The Department contends the lieutenant position is FLSA-exempt and denies liability. 44 opt-in plaintiffs joined after conditional collective-certification.
  • The parties negotiated a settlement that conditions relief on: (1) this Court’s approval, (2) amendment of Appendix K to the Minnesota Commissioner’s Plan by the Department of Management and Budget, and (3) ratification of that amendment by the Minnesota Legislature by the end of the 2017 session. The agreement becomes void if legislative ratification does not occur by adjournment.
  • The parties jointly moved for court approval of the settlement and a stay of proceedings pending legislative action.
  • The Court found it could not meaningfully review or approve settlement terms that remain subject to uncertain state executive and legislative action and federalism concerns, so it held the approval motion in abeyance but granted a stay.
  • The Court ordered the parties to file a joint report proposing a scheduling plan within 7 days after any final legislative action or the conclusion of the 2017 legislative session.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the Court should approve the parties’ FLSA settlement now Settlement is a fair, reasonable resolution of a bona fide FLSA dispute and requires court approval Settlement is acceptable; contends lieutenants are exempt but agreed to settlement terms Denied as premature — Court cannot assess fairness because material settlement terms remain contingent on state action and raise federalism concerns
Whether to stay proceedings pending state legislative action Stay requested to allow parties to seek legislative ratification and avoid further litigation if amendment passes Jointly requested stay; will dismiss if legislature ratifies, otherwise seek lifting Stay granted to conserve resources and control docket; parties must report within 7 days after final legislative action or session end

Key Cases Cited

  • Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (standard for court review of FLSA settlements)
  • D.A. Schulte, Inc. v. Gangi, 328 U.S. 108 (1946) (settlement reflects bona fide dispute when it is a reasonable compromise)
  • Horne v. Flores, 557 U.S. 433 (2009) (institutional reforms raise federalism concerns)
  • Lewis v. Casey, 518 U.S. 343 (1996) (limits on federal courts taking control of state institutions)
  • Cottrell v. Duke, 737 F.3d 1238 (8th Cir. 2013) (stay power incidental to court’s docket control)
  • Landis v. N. Am. Co., 299 U.S. 248 (1936) (foundational stay-of-proceedings doctrine)
  • Sierra Club v. U.S. Army Corps of Eng’rs, 446 F.3d 808 (8th Cir. 2006) (district court discretion to stay proceedings)
  • Clinton v. Jones, 520 U.S. 681 (1997) (district court control over litigation management)
  • Already, LLC v. Nike, Inc., 568 U.S. 85 (2013) (mootness and Article III limitations)
  • Beck v. Mo. State High Sch. Activities Ass’n, 18 F.3d 604 (8th Cir. 1994) (if court cannot grant effective relief, case is moot)
Read the full case

Case Details

Case Name: Stainbrook v. Minnesota Department of Public Safety
Court Name: District Court, D. Minnesota
Date Published: Mar 8, 2017
Citation: 239 F. Supp. 3d 1123
Docket Number: Case No. 15-cv-4198 (WMW/LIB)
Court Abbreviation: D. Minnesota