Company Cries “Fowl” Over Jury Verdict, Fourth Circuit Agrees — Poultry Workers’ State Law Wage Claims Are Preempted by Federal Law

In a victory for limiting the avenues available to employees covered by collective bargaining agreements, the Fourth Circuit Court of Appeals held that federal law preempts state law claims for unpaid wages where a CBA is implicated.  As a result, the Fourth Circuit reversed a jury verdict in favor of unionized employees in Barton v. House of Raeford Farm, Inc.

There, production and maintenance workers at a poultry plant alleged that their employer violated the FLSA and South Carolina wage-hour law by, among other things, paying them only for time spent on the production line processing chickens.  This “line time” did not include time spent donning and doffing protective gear, walking to and from the line, or washing gear before and after work.  The workers argued that they should have been paid for this time, and not just for their “line time.”  The workers were members of a union and subject to a CBA, which spelled out their hours of work and rates of pay.  But the CBA did not expressly specify how employees’ compensable time would be calculated.

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