Is Federal Court Barred from Hearing Collective Action Claims by Employees in Another State?

Fischer v. Federal Express Corp. asks whether a federal court in one state is barred from hearing collection action claims by employees in another state.

The Case: Fischer v. Federal Express Corp.

The Court: Supreme Court of the United States

The Case No.: 22-396

The Plaintiff: Fischer v. Federal Express Corp.

Christina Fischer, the plaintiff in the case, worked as a FedEx security specialist in Pennsylvania. Fischer worked at FedEx for ten years. Security specialists like Fischer regularly worked over 40 hours per week, but FedEx classifies them as salaried employees. Under the Fair Labor Standard Act of 1938, salaried employees are exempt from overtime pay. Fischer filed an FLSA collective action in federal district court in Pennsylvania seeking unpaid overtime from FedEx. In the complaint, Fischer argued that she was ineligible for the Act's overtime exemption. Two security specialists in other states "opted in" to the collective action Fischer filed.

The Defendant: Fischer v. Federal Express Corp.

The defendant in the case, Federal Express Corp. (also known as FedEx Corporation, FDX Corporation, FedEx, etc.), is an American multinational conglomerate holding company focused on transportation, e-commerce, and business services. FedEx is based out of Memphis, Tennessee.

The Case: Fischer v. Federal Express Corp.

In 2017, the justices' decision in Bristol-Myers Squibb v. Superior Court of California limited certain personal-injury lawsuits against businesses to residents of a single state. The decision allowed companies to convince state courts to question the validity of lawsuits brought by out-of-state plaintiffs over out-of-state actions. In Fischer v. Federal Express Corp., the court considered whether Bristol-Myers Squibb also barred a federal court in one state from hearing collective-action claims against FedEx by employees in another state. The 3rd Circuit court concluded that it does. The employees argue that the 3rd Circuit's decision contradicts longstanding federalism and due-process doctrines, investing state courts with a narrower personal jurisdiction than federal courts and cutting the power of collective actions off at the knees. Based on these arguments, the employees urged the court to reinstate their collective action against the massive shipment and transportation company.

If you have questions about filing a California overtime lawsuit, don't hesitate to contact Blumenthal Nordrehaug Bhowmik DeBlouw L.L.P. Experienced employment law attorneys are ready to assist you in various law firm offices in San Diego, San Francisco, Sacramento, Los Angeles, Riverside, and Chicago.