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Lauren Houstonv.Country Club, Inc.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.16-17484
DecidedApril 18, 2018
Reporter252 F.3d 1208
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilEmployment LawStatutory InterpretationClass ActionFirst ImpressionAppellate Procedure
Case Summary

Employees of a Georgia entertainment venue alleged that the company misclassified them as independent contractors and failed to pay minimum wages and overtime under the Fair Labor Standards Act. Several employees filed written consents to join the collective action, but the district court denied the named plaintiff’s motion for conditional certification as untimely and later ruled that the opt-in employees had never become parties. The Eleventh Circuit reversed that ruling. It held that an employee becomes a party plaintiff under the statute by filing written consent with the court; conditional certification is a case-management device used to facilitate notice, not a prerequisite to party status. The court explained that the statute requires written consent and does not require a prior judicial finding that the employee is similarly situated. Because the opt-in employees had timely filed their consents and had appellate standing, the court remanded for further proceedings concerning the collective action.

Opinion

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