Bigger v. Facebook, Inc.

Federal 7th Circuit Court
Civil Court
Fair Labor Standards Act
Citation
Case Number: 
No. 19-1944
Decision Date: 
January 24, 2020
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed and vacated in part and remanded

In action under Fair Labor Standards Act alleging that defendant-employer failed to pay plaintiff overtime wages in her Client Solutions Manager position, Dist. Ct. erred in authorizing notice of instant action to be sent to entire group of similarly situated employees as proposed by plaintiff for purposes of allowing them to opt into instant lawsuit, where defendant asserted that many of proposed notice recipients had entered into arbitration agreements that would preclude them from joining instant action. On remand, Dist. Ct. should allow parties to submit additional evidence on existence of valid arbitration agreements, and if defendant proves that certain proposed recipients entered into valid arbitration agreements or if plaintiff does not contest that said employees entered into said agreements, Dist. Ct. cannot authorize issuing notice to said employees. Dist. Ct., though, did not err in denying defendant’s summary judgment motion, where record contained dispute as to whether plaintiff qualified as overtime-exempt administrative employee, where record failed to establish whether plaintiff’s work customarily and regularly supported defendant’s general business operations or management.