In the case of Noll v. Flowers Foods Inc., Timothy Noll filed a collective action lawsuit against Flowers Foods, Lepage bakeries, and CK Sales (collectively called “the Defendants”). Noll filed this lawsuit on behalf of himself and other similarly situated individuals. The lawsuit claimed that the Defendants had misclassified them as independent contractors and denied them overtime wages.
The collective group consisted of individuals who worked as distributors for the Defendants. Noll sought recovery of unpaid overtime wages under the federal Fair Labor Standards Act (FLSA). The Defendants filed for a summary judgment which the court denied. The court found that the distribution activity fell under the Motor Carrier Act (MCA) exemption to the FLSA. However, some members of the collective may still be entitled to overtime wages under the Technical Corrections Act (TCA).
Despite that, the court granted the defendant’s motion to decertify the FLSA collective action because Noll failed to provide sufficient evidence to support his claim and demonstrate that the small vehicle exception applied. The court emphasized that the burden of proof for the TCA exception fell on Noll, and he had not met that burden.
Based on these findings, the court granted the motion for decertification, dismissing the FLSA and declaratory judgment claims of the opt-in individuals. Noll’s FLSA and declaratory judgment claim was permanently dismissed because he couldn’t substantiate his eligibility for the TCA exception.
Key lessons from this case:
- The court may consider the practical impact of an employee’s transportation activities on interstate commerce.
- The MCA exemption can exempt certain distribution activities from FLSA overtime provisions unless an exception applies.
- The TCA exception to the MCA exemption may allow distributors to claim FLSA overtime wages if they use personal vehicles for transportation.
If you want to know more about overtime regulations, read our guide on Maine Overtime Laws.
