FLSA Collective Action Dismissed for Lack of Jurisdiction: Third Circuit | Practical Law
In Camesi v. University of Pittsburgh Medical Center, the US Court of Appeals for the Third Circuit dismissed a consolidated appeal of two Fair Labor Standards Act (FLSA) collective actions for lack of jurisdiction. The court held that the named plaintiffs could not appeal the collective action decertification order on behalf of the opted-in plaintiffs because the named plaintiffs voluntarily dismissed their individual claims. Further, the named plaintiffs no longer had a sufficient interest in the litigation to serve as representatives of the opted-in plaintiffs.