In re: Jimmy John’s Overtime Litigation

In action by several assistant store managers employed by different franchisees of Jimmy John’s against franchisor Jimmy John’s alleging violation of Fair Labor Standards Act (FSLA) with respect to non-payment of overtime, Dist. Ct. lacked authority to issue anti-suit injunction that would preclude other assistant store managers from filing similar claims in other district courts against franchisees until claims of instant store managers against Jimmy John’s (on alleged joint employer theory) had been resolved. Ct. of Appeals rejected Jimmy John’s claim that All Writs Act allowed issuance of anti-suit injunction in instant matter to prevent duplicative litigation, to avoid inconsistent rulings and to protect integrity of Dist. Ct.’s pretrial orders regarding discovery on joint employer issue and notice procedures, since: (1) Jimmy John’s is not party in enjoined franchisees cases and said franchisees could not be joined in instant case where Dist. Ct. lacked personal jurisdiction over out-of-state franchisees; (2) any potential effect that decision in enjoined cases could have on instant action did not justify issuance of anti-suit injunction; and (3) Dist. Ct. did not mention need to protect its pretrial rulings as reason for issuance of anti-suit injunction. Also, issuance of anti-suit injunction was not appropriate under Dist. Ct.’s inherent authority, where Dist. Ct. failed to make necessary findings regarding traditional equitable requirements for issuance of injunction in compliance with Rule 65 such as existence of irreparable harm for which there is no adequate remedy at law.