Tyson Foods, Inc. v. Bouaphakeo

Tyson Foods, Inc. v. Bouaphakeo, 577 U.S. ___ (2016), is a significant case in the realm of United States labor law and class action lawsuits. The case was heard by the Supreme Court of the United States, which delivered its opinion on March 22, 2016. The decision addressed critical issues regarding the use of statistical sampling in proving liability and damages in class action and collective action lawsuits under the Fair Labor Standards Act (FLSA) and the Iowa Wage Payment Collection Law.

Background

The plaintiffs in this case were employees at a Tyson Foods pork processing plant in Iowa. They filed a lawsuit against Tyson Foods, alleging that the company failed to pay them for the time spent donning and doffing protective equipment and walking to and from their workstations. The plaintiffs sought overtime pay under the FLSA and the Iowa Wage Payment Collection Law, arguing that these activities were integral and indispensable to their hazardous work, and thus should be compensable.

Case History

The case was initially filed in the United States District Court for the Northern District of Iowa. The plaintiffs sought to certify the lawsuit as a class action under Rule 23 of the Federal Rules of Civil Procedure and as a collective action under the FLSA. The District Court certified the class and collective actions, and the case proceeded to trial. The jury returned a verdict in favor of the plaintiffs, awarding them $2.9 million in unpaid wages.

Tyson Foods appealed the decision to the United States Court of Appeals for the Eighth Circuit, arguing that the class certification was improper because the plaintiffs had used statistical sampling to establish liability and damages. The Eighth Circuit upheld the District Court's decision, leading Tyson Foods to petition the Supreme Court for a writ of certiorari.

Supreme Court Decision

The Supreme Court, in a 6-2 decision, affirmed the lower court's ruling. Justice Anthony Kennedy, writing for the majority, held that the use of statistical sampling was appropriate in this case to determine the average time employees spent on the contested activities. The Court found that each class member could have relied on that sample to establish liability if they had brought individual lawsuits, thus the class action could proceed in the same manner.

The Court's decision clarified the circumstances under which statistical evidence could be used in class action lawsuits, particularly in cases involving the FLSA. It was seen as a victory for employees, making it easier for groups of workers to file class and collective actions against their employers.

Implications

The ruling in Tyson Foods, Inc. v. Bouaphakeo has significant implications for labor law and class action litigation. It affirmed that statistical sampling is a valid method for proving liability and damages in class action lawsuits, especially when individualized evidence is impractical to collect. This decision is particularly relevant in employment law, where workers' actions and experiences are often similar, and individual record-keeping may be lacking.

See Also

• Class action
• Fair Labor Standards Act
• Supreme Court of the United States
• United States labor law