Espenscheid v. DirectSat USA, LLC

In class action seeking to enforce Fair Labor Standards Act arising out of wages paid to 2,341 technicians hired to install and repair home satellite dishes, Dist. Ct. did not err in entering order that de-certified class after finding that necessity to conduct 2,341 separate damages hearings as part of class action would be impractical. Record showed that each technician was paid on per piece basis, and thus had different experiences with respect to hours worked and overtime paid. Fact that plaintiffs selected 42 individuals as “representatives” of all 2,341 technicians did not cure multiplicity problem where criteria for said selection was not divulged to Dist. Ct., and where record would not support general claim that all 2,341 technicians performed roughly same amount of regular and overtime work.