More Than Morgan: Federal Court Decertifies Nationwide FLSA Collective Action Despite Arguments Likening it to Plaintiff-Friendly Result in Morgan v. Family Dollar

Last month, we reported on a ruling handed down by Judge Scott Coogler, a U.S. District Court Judge in Alabama, decertifying a nationwide FLSA collective action of store managers who claimed that they were misclassified as overtime-exempt. As is common in store manager cases under the FLSA, the plaintiffs in that case, Knott v. Dollar Tree Stores, essentially argued that they should be thought of as managed rather than managing—this, despite the fact that each was the highest-ranking employee in his or her store. Who ran the stores, one might ask? The district managers…the regional managers…the corporate manual…anyone but the store managers, the plaintiff-store managers argued. In decertifying the collective, Judge Coogler made clear not only that the FLSA’s executive exemption was in play, but also that its duty-specific nature left no room to force Dollar Tree to argue the defense on a one size fits all basis.

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