Court Grants Chipotle’s Motion to Decertify FLSA Class Action
Chipotle Mexican Grill Inc. won decertification of a class action comprising more than 500 management trainees in 37 states when a federal court ruled that there were too many differences in the trainees’ ability to perform managerial duties, causing the action to fail the predominance test. Scott v. Chipotle Mexican Grill Inc., No. 12-8333, (S.D.N.Y., order entered March 29, 2017).
Seven named plaintiffs won conditional class certification in June 2013, after which 516 additional plaintiffs opted in. The plaintiffs, who worked as “apprentices,” were temporary workers training for positions as restaurant general managers. The complaint alleged apprentices were classified as exempt and illegally denied overtime even if they spent most of their time on nonmanagerial tasks such as preparing food or serving customers, violating the Fair Labor Standards Act (FLSA) and state labor laws. However, the court found that the plaintiffs’ testimony contained too much conflicting information about the apprentices’ responsibilities. “[T]he apprentices had vastly different levels and amounts of authority in exercising managerial tasks,” the court said. “If a jury were to determine that one apprentice is properly classified as exempt in Washington [under Chipotle’s anticipated defenses], it does not follow that all apprentices would be exempt across the country.”
Issue 629
