Jury Verdict in Favor of Meat Processor Upheld in Unpaid Wages Class Action.

On the same day it upheld a large jury verdict in favor of employees in a similar class action against the same employer, the Eighth Circuit upheld a jury verdict in favor of the meat processor in this case.  The plaintiffs represented a class of employees at a meat-processing facility in Columbus Junction, Iowa. They sued the meat processor for not paying wages due under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. § 201 et seq., and the Iowa Wage Payment Collection Law (IWPCL), Iowa Code 91A.1 et seq. The plaintiffs alleged that they had been uncompensated for time spent “donning“ and “doffing” safety apparel and walking from where the apparel was located to and from the job site. The district court entered partial summary judgment for the meat processor, ruling that the claims for donning, doffing and walking during the 35-minute lunch period were not compensable. The jury returned a verdict for the processor on the other claims, finding that the plaintiffs did not prove that the activities in question were “integral and indispensable to a principal activity.” On appeal, the Eighth Circuit affirmed, finding that sufficient evidence existed that the disputed activities were not integral and indispensable class-wide. The court also found that the trial court did not err in allowing the jury to hear evidence supporting the processor's good faith defense. Summary judgment was properly granted as to the mealtime claims because the evidence showed that the mealtime period was primarily for the employees’ benefit, not for the benefit of the employer. Donning and doffing during the 35-minute meal period was thus not compensable.  Guyton v. Tyson Foods, No. 13-2036 , 2014 U.S. App. LEXIS 16278 (8th Cir. Iowa Aug. 25, 2014).


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