TYSON FOODS v. BOUPHAKEO

Citation: Tyson Foods, Inc. v. Bouaphakeo, 577 U.S. ___ (2016)

136 S. Ct. 1036; 194 L. Ed. 2d 124; 2016 U.S. LEXIS 2134

Brief Fact Summary: Plaintiffs sued the defendant for violations of the Equal Labor Practices Act and the Iowa Wage Payment Collection Statute in federal district court. Plaintiffs served in the cutting and retrimming and killing divisions at an Iowa pork processing facility. Plaintiffs needed to wear protective gear as part of their employment, and the FLSA allowed them to be paid for time spent doing "integral and indispensable" stuff for their employment. Plaintiffs argued that "donning and doffing," the time spent putting on and taking off their protective gear, met the norm, and that the defendant should have paid them for the time they did so. Instead,defendant compensated some employees for four to eight minutes of that activity and others for none at all. Plaintiffs sought to certify their class under Rule 23 of the Federal Rules of Civil Procedure. Defendant argued that the class should not be certified because of the individual variance in the employees' protective gear.

Procedural Steps: Present and former employees of Tyson Foods, Inc. (Tyson) at the meat-processing facility of the company in Storm Lake, Iowa are Bouaphakeo and the rest of the applicant class. The employees worked on a system where they were only payed for the time they were at their workstations and the production line was moving. The workers sued Tyson and claimed that by not providing sufficient wages for the time spent putting on and taking off protective equipment at the beginning and end of the work day and lunch break, the corporation violated the Fair Labor Standards Act of 1938 and the Iowa Wage Payment Collection Statute. The class was approved by the district court and the jury returned a verdict in favor of the plaintiffs and awarded several million dollars in damages.Tyson appealed and argued that the district court erred in certifying the class of plaintiffs because substantive discrepancies between the plaintiffs rendered class certification inappropriate. Tyson also claimed that the class should be decertified because facts presented at trial demonstrated that the acts of the company did not harm any members of the class and thus had no right to compensation. The U.S. Court of Appeals for the Eighth Circuit affirmed the district court's certification of the plaintiff class.

Primary Issue: Whether the company violated the Fair Labor Standards Act of 1938 and the Iowa Wage Payment Collection Law by not paying appropriate compensation for the time spent putting on and taking off protective clothing at the beginning and end of the work day and lunch break.

Synopsis of Rule of Law Prior to the Case: When plaintiffs sued Tyson for not paying wages due under the Fair Labor Standards Act, and the Iowa Wage Payment Collection Law, a jury returned a verdict for the class. The FLSA prohibits the employment of any person for a workweek longer than forty hours unless such employee receives compensation for his employment in excess of the hours above specified at a rate not less than one and one-half times the regular rate at which he is employed.

Decision: The class action was based on one question, despite differences among class members, and the class was therefore properly accredited. In addition, while there would be no right to restitution for those class members who had not been harmed, the judgment had not yet been dispersed, and therefore the district court can review the disbursement on remand.

Summary of Decision: The District Court did not err in certifying and maintaining the class.

Opinion about the Decision: I think under one common issue, the class members were joined, and despite differences between the members, that satisfies the requirements for a class action suit.

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