Weil v. Metal Techs., Inc.
United States Court of Appeals for the Seventh Circuit
January 18, 2019, Argued; May 29, 2019, Decided
Nos. 18-2556 & 18-2440
[*354] BARRETT, Circuit Judge. Brian Weil and Melissa Fulk filed class and collective actions against Metal Technologies, alleging wage violations under the Fair Labor Standards Act and Indiana wage laws. They had two basic complaints. First, they argued that Metal Technologies unlawfully paid employees only for the hours that they were scheduled to work even when employees' timestamps showed that they were clocked in for longer than that. The district court conditionally certified—but then later decertified—those claims. After decertification, [**2] the plaintiffs proceeded in their individual capacities and secured a very modest damages award. Second, the plaintiffs contended that Metal Technologies withheld wages from employees' paychecks for uniform rentals, even though Indiana law authorized withholding only for uniform purchases. The district court entered judgment for the class on the wage-deduction claims, which had been split into two time periods, and they won a much larger damages award.
Both sides appealed. The plaintiffs argue that the district court should not have decertified the time-rounding claims, and Metal Technologies insists that Indiana law permitted it to deduct wages to cover uniform rentals. Each side thinks that the district court should have awarded it costs. And while the plaintiffs think that they have recovered too little in attorneys' fees, the defendants say that the plaintiffs have recovered too much.
If the law remained as it stood on the day that the case was argued, we would affirm the district court across the board. After argument, however, the Indiana legislature introduced a wrinkle: it amended its wage-deduction law to authorize withholding for uniform rentals, and it made that amendment [**3] retroactive. Given this turn of events, we affirm the district court's decertification order but vacate the judgment and remand the case for the district court to reconsider the wage-deduction claim in light of the new law. That will likely also require the district court to recalculate attorneys' fees and costs.
Metal Technologies is a manufacturer of automobile parts in Bloomfield, Indiana. It employs around 500 workers. These employees work one of three shifts throughout the day, which overlap by 30 minutes to ensure time to clean up and exchange information with the next shift. Metal Technologies keeps track of employees' time with an electronic time clock. It calculates pay based on scheduled shifts rather than time-clock punches—so employees are typically paid for 40 hours per week, and if they need to go over, they must fill out an overtime authorization form. Metal Technologies also deducts wages from employees who elect to rent work uniforms.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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925 F.3d 352 *; 2019 U.S. App. LEXIS 15946 **; 169 Lab. Cas. (CCH) P61,968
BRIAN A. WEIL and MELISSA D. FULK, individually and on behalf of others similarly situated, Plaintiffs-Appellees/Cross-Appellants, v. METAL TECHNOLOGIES, INC., Defendant-Appellant/Cross-Appellee.
Subsequent History: On remand at, Costs and fees proceeding at Weil v. Metal Techs., Inc., 2019 U.S. Dist. LEXIS 192619 (S.D. Ind., Nov. 6, 2019)
Prior History: [**1] Appeal from the United States District Court for the Southern District of Indiana, Terre Haute Division. No. 2:15-cv-00016 — Jane Magnus-Stinson, Chief Judge.
Weil v. Metal Techs., Inc., 2015 U.S. Dist. LEXIS 135991 (S.D. Ind., Oct. 6, 2015)
district court, wage-deduction, clock, employees, time-rounding, costs, certification, retroactive, decertify, wages, collective action, compensated, deduct, individual claim, attorney's fees, plaintiffs', scheduled, rentals
Civil Procedure, Special Proceedings, Class Actions, Labor & Employment Law, Wage & Hour Laws, Remedies, Governments, Legislation, Effect & Operation, Retrospective Operation, Assignments & Deductions, Costs & Attorney Fees, Costs, Preliminary Considerations, Federal & State Interrelationships, Justiciability, Mootness, Class Actions, Certification of Classes, Decertification