In a big win for employers facing hybrid off-the-clock class actions, last week the U.S. District Court for the Southern District of New York denied plaintiffs’ motion to certify a class action under three different state wage laws (New York, Illinois and District of Columbia) and granted the motion to decertify a nationwide FLSA collective action against a major U.S. bank with extensive domestic and global operations. In Ruiz v. Citibank, the court held that in the absence of an illegal company policy, “systemic violations at the branch level” were insufficient to support a nationwide class or collective action, both of which required evidence of uniform nationwide managerial conduct.
Home > Federal Law Articles > Class Actions > Wage & Hour Class Actions > Second Circuit Federal District Court Denies Rule 23 Class Certification and Grants Decertification of FLSA Collective Action