On TV, parties often win their court cases as a result of a massive revelation during trial in open court. In real life, parties often sow the seeds of their success before the trial even starts. A truck driver’s recent unpaid overtime case illustrates just how critical pre-trial motions can be in a Fair Labor Standards Act case. If you have questions about litigating your FLSA case, retain an experienced Atlanta unpaid overtime lawyer to provide the advice and advocacy you need.
The truck driver, K.S., initiated an FLSA lawsuit in 2022, alleging she worked substantial amounts of unpaid overtime. Specifically, she asserted that she worked roughly 70 hours per week but never received any overtime compensation as required by federal law.
The employer contended that federal law did not require it to pay the driver overtime compensation. Specifically, the employer argued that K.S. was an independent contractor, not an employee. The employer furthermore contended that it did not owe K.S. overtime because an exemption to the FLSA’s overtime requirement—the Motor Carrier Act Exemption—applied to its case.
Each of K.S. and the employer filed a motion for summary judgment. A motion for summary judgment is one where the party asks the trial court to determine that it is entitled to a ruling in its favor “as a matter of law” on a particular claim (or claims). This occurs when the opposing side cannot possibly succeed on a claim, even if the court were to view all the facts in dispute in the most favorable manner to the opposing side.
Using — and winning — a motion for summary judgment in a FLSA case can be vital to the overall success of your case. In the driver’s case, the trial judge ruled in her favor on several key points. The court’s summary judgment order expressly found that K.S. was an employee and not an independent contractor. The court also ruled that the employer had waived (a/k/a forfeited) its right to assert any arguments based on the Motor Carrier Act Exemption.
These summary judgment “wins” were massively helpful when the driver’s case went to trial. Before the trial began, the judge issued a ruling stating that the only things to be tried were (1) whether or not the employer willfully violated the FLSA, (2) the amount of overtime pay owed to K.S., and (3) attorney’s fees.
Because the court erected these boundaries, that allowed the driver to make and win several motions “in limine.” (A motion in limine asks the court to exclude specific evidence or bar the other side from presenting certain arguments at trial.) A motion in limine is one way to keep out evidence or arguments on issues that you already won at the lawsuit’s summary judgment phase.
No Relitigating Decided Issues
In K.S.’s case, this was essential because the employer made it clear in its court papers that it intended to make reference at trial to the Motor Carrier Act Exemption and to assert that the driver was an independent contractor who was “not entitled to overtime wages pursuant to the federal law,” declaring those issues to be “disputed.”
That was incorrect, and those statements raised the judge’s concern that the employer intended to do what it was not allowed to do, which was relitigate issues that it had already contested—and lost—at the summary judgment phase of the lawsuit.
Under the legal concept known as the “law-of-the-case doctrine,” parties may not re-raise at trial issues that the court previously resolved on summary judgment. A ruling that the judge reaches in summary judgment is just as binding as if a jury had reached it at the close of the trial. As a result, the court granted almost all of the driver’s motions in limine, thereby protecting her at trial.
As this employee’s case shows, unpaid overtime cases are often multi-faceted matters that require in-depth knowledge of the procedural rules and the procedural tools they make available to you. Utilizing these tools to your maximum benefit can go a long way in ensuring you receive a fair and full judgment you deserve.
For answers to your questions about the FLSA and overtime compensation, get in touch with the Atlanta wage and hour attorneys at Parks, Chesin & Walbert. Our team has extensive experience handling a full range of overtime cases, enabling us to provide the knowledgeable advice you need. Contact us through this website or at 404-873-8048 to schedule a consultation today.