Syrja v. Westat, Inc., 756 F. Supp. 2d 682

Westat conducted NHANES data collection across multiple temporary stands nationwide, staffed by field interviewers and managers.
Field interviewers set their own schedules, travel between stands, and reported hours on weekly timesheets for payroll processing.
Syrja, a former Westat field interviewer (2005–2008), claimed he regularly worked overtime but was not compensated and was told not to report >40 hours per week.
Syrja alleges a class of similarly situated Westat employees existed who were denied overtime or instructed not to report overtime hours.
He admits he did not record any hours over 40 on his timesheet and did not maintain separate records of actual hours worked.
Westat maintains it pays all overtime hours, including unauthorized overtime, and denies a uniform national policy against overtime compensation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case should be conditionally certified as a 216(b) collective action.	Syrja; similarly situated employees exist and share illegal pay practices.	Westat; case involves varied circumstances across locations; not suitable for collective action.	Denied.
Whether Syrja and putative class members are sufficiently similarly situated.	Syrja and others faced the same policy of underpaying overtime and instructing not to report overtime.	Westat; deposee testimony shows substantial variance in how jobs are performed and supervised.	Denied as part of overall denial; not sufficiently demonstrated at notice stage.
Whether the case is manageable as a collective action at the notice stage.	Manageability concerns are premature at notice stage and appropriate to address later.	Case would require extensive individualized inquiries across many locations and time periods.	Denied due to lack of a common national policy and extensive individualized inquiries required.
Whether equitable tolling should apply to potential class members’ FLSA claims.	Delays from prior stages warrant tolling for putative class members.	Unknown prospective plaintiffs are not entitled to tolling absent extraordinary circumstances.	Denied; no extraordinary circumstances shown for tolling.

Hoffmann-LaRoche, Inc. v. Sperling, 493 U.S. 165 (U.S. 1989) (§ 216(b) class actions promote judicial economy)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading standards require plausible claims)