Creason v. Elanco US Inc.

Plaintiff filed a lawsuit under the Indiana Wage Payment Statute alleging that his former employer underpaid his weekly salary by automatically enrolling him in an vacation buy program. Plaintiff filed the lawsuit in state court and sought to represent a class of similarly situated workers. Defendant removed the case to federal court under the Class Action Fairness Act and ultimately prevailed. The Seventh Circuit affirmed, explaining that while the district court may have incorrectly declined to act on class certification, its decision in favor of the defendant on the merits of the case was correct. (KIRSCH and KOLAR, concurring)