Harper v. Southwest Airline Co.

District Court, D. Nevada·Decided August 30, 2025·No. 2:24-cv-01799·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 JALA HARPER, Case No.: 2:24-cv-01799-APG-DJA

4 Plaintiff Order (1) Granting in Part Southwest’s Motion to Dismiss, (2) Denying Southwest’s 5 v. Motion for Sanctions, and (3) Granting Harper’s Motion to Extend Time 6 SOUTHWEST AIRLINES CO., [ECF Nos. 26, 27, 33] 7 Defendant

8 Jala Harper sues her former employer, Southwest Airlines Co., asserting claims for 9 discrimination based on her race, sex, and disability, creating a hostile work environment, 10 retaliation, tortious discharge, and intentional infliction of emotional distress (IIED). She also 11 sues Southwest under the Fair Labor Standards Act (FLSA) and Nevada law on behalf of a class 12 of workers for allegedly failing to pay overtime, and under Nevada law for failing to pay for all 13 hours worked and failing to timely pay wages owed upon separation. 14 Southwest moves to dismiss eight of Harper’s claims, arguing that airline employees who 15 perform work related to carrier operations are exempt from overtime laws and that Harper has 16 not plausibly alleged the elements of her individual claims. Southwest also moves for sanctions 17 against Harper and her counsel under Federal Rule of Civil Procedure 11, arguing that Harper’s 18 wage and hour claims lack a good faith basis supported by law or a nonfrivolous argument to 19 extend, modify, or reverse existing law. Specifically, Southwest contends that courts have 20 consistently held that customer service employees fall within the air carrier exemption. 21 Southwest also argues that Harper’s counsel failed to conduct a reasonable and competent 22 inquiry prior to filing her claims because Southwest informed Harper’s counsel that it has a 23 policy of paying for boot time. Harper responds that her job is not related to Southwest’s carrier 1 operations, she has plausibly alleged each of her individual claims, and she had a good faith basis 2 for bringing her overtime claims. 3 I dismiss Harper’s overtime claims because she is exempt from the FLSA and Nevada 4 overtime provisions. I deny Southwest’s motion to dismiss her individual claims because she

5 has plausibly alleged facts that, taken in the light most favorable to her, state a valid claim. I 6 deny Southwest’s motion for sanctions because Harper had a good faith basis for her claims. I 7 grant Harper’s motion to extend time. 8 I. BACKGROUND1 9 Southwest hired Harper to work as a remote customer service representative in 10 September 2022. After two weeks of in-person training, Harper began working remotely from 11 home where she attended virtual training sessions with her team lead, Mathew Parker. During 12 their first training session, Parker told Harper, “‘[y]ou have such a pretty smile,’” which made 13 her feel uncomfortable. ECF No. 24 at 4. Parker repeated this statement again at the end of the 14 training. During the training, Parker asked Harper personal questions unrelated to work such as

15 if she liked to travel or what she liked to do outside of work. Harper was a black woman in her 16 thirties and Parker was a white man in his forties. 17 Because she found this interaction uncomfortable and inappropriate, Harper kept her 18 camera off during her second training session with Parker a week later. Parker allegedly became 19 enraged and yelled at Harper to turn on her camera. Parker then became more upset and the 20 training session “turned into a fifty-six minute diatribe as Mathew Parker belittled Ms. Harper’s 21 work ethic, character, and personal views.” Id. at 5. In response to Harper’s attempts to 22 23

1 All facts are taken from the first amended complaint (ECF No. 24). 1 deescalate the situation, Parker accused her of being “‘manipulative’” because she could “‘speak 2 well for an African American woman.’” Id. 3 Harper reported her experience to Southwest’s manager of operations and then, after 4 finding the response unsatisfactory, reached out its vice president of customer service.

5 Meanwhile, Parker scheduled another training session and warned Harper not to remove it. 6 Harper had received fewer training sessions than her peers at this point. Southwest then 7 switched Harper to a new team lead without disciplining Parker. Harper asserts that her 8 interactions with Parker, the unsatisfactory response from management, and the transfer to a new 9 team lead caused her to have a panic attack, break out in hives, and go to the emergency room. 10 She suffered several panic attacks in December 2022 that resulted in further emergency room 11 visits. 12 Based on a mental health professional’s advice, Harper took leave from December 2022 13 through February 2023, which Southwest approved. After Harper returned to work in March 14 against her healthcare professional’s advice, she determined that she needed additional time off.

15 Harper informed Southwest that she needed additional time off and Southwest terminated her 16 that same week. Southwest’s stated reason was that she “‘greatly exceeded the number of 17 absences Customer Representatives are allowed to have while they are on probation.’” Id. at 8 18 (simplified). Harper denies that she was still on probation at that time. 19 Harper alleges that during her time at Southwest, she spent time each workday booting up 20 her computer, logging in, connecting to Southwest’s virtual private network (VPN), logging into 21 the timekeeping software, and then repeating this process in reverse at the end of her shift. Boot 22 time took approximately five minutes. Harper alleges that she and other class members were not 23 paid for this boot time and typically worked 8 hours per shift, 40 hours per week. 1 II. ANALYSIS 2 In considering a motion to dismiss, I take all well-pleaded allegations of material fact as 3 true and construe the allegations in a light most favorable to the non-moving party. Kwan v. 4 SanMedica Int’l, 854 F.3d 1088, 1096 (9th Cir. 2017). However, I do not “assume the truth of

5 legal conclusions merely because they are cast in the form of factual allegations.” Navajo Nation 6 v. Dep’t of the Interior, 876 F.3d 1144, 1163 (9th Cir. 2017). A plaintiff must make sufficient 7 factual allegations to establish a plausible entitlement to relief. Bell Atl. Corp. v. Twombly, 550 8 U.S. 544, 556 (2007). Such allegations must amount to “more than labels and conclusions, [or] a 9 formulaic recitation of the elements of a cause of action.” Id. at 555. A claim is facially 10 plausible when the complaint alleges facts that allow the court to draw a reasonable inference 11 that the defendant is liable for the alleged misconduct. Ashcroft v. Iqbal, 556 U.S. 662, 678 12 (2009). 13 A. Harper is exempt from both Nevada and the FLSA’s overtime rules. 14 Southwest argues that both Nevada and federal overtime rules exempt airline employees

15 and employees covered by a collective bargaining agreement (CBA). Harper responds that her 16 job is not closely related to Southwest’s transportation activities, so the exemption for airline 17 employees does not apply. She also argues that at least part of her employment was not covered 18 by a CBA, so that exemption does not apply either. 19 The FLSA requires employers to pay overtime rates for hours worked in excess of 40 20 hours. 29 U.S.C. § 207(a)(1). Nevada similarly requires overtime rates for hours worked above 21 40 hours in a week or either 8 or 10 hours in a workday based on the employee’s schedule. Nev. 22 Rev. Stat.

Free access — add to your briefcase to read the full text and ask questions with AI

Harper v. Southwest Airline Co., (D. Nev. 2025).

Harper v. Southwest Airline Co. (Harper v. Southwest Airline Co.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Thibodeaux v. Executive Jet Internaional, Inc.
328 F.3d 742 (Fifth Circuit, 2003)
Brandon Valdivieso v. Atlas Air, Inc.
305 F.3d 1283 (Eleventh Circuit, 2002)
McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Harris v. Forklift Systems, Inc.
510 U.S. 17 (Supreme Court, 1993)
Faragher v. City of Boca Raton
524 U.S. 775 (Supreme Court, 1998)
Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jesus Briones v. Riviera Hotel & Casino
116 F.3d 379 (Ninth Circuit, 1997)
Sands Regent v. Valgardson
777 P.2d 898 (Nevada Supreme Court, 1989)
Nelson v. City of Las Vegas
665 P.2d 1141 (Nevada Supreme Court, 1983)
D'Angelo v. Gardner
819 P.2d 206 (Nevada Supreme Court, 1991)
Pope v. MOTEL 6
114 P.3d 277 (Nevada Supreme Court, 2005)
Kwan v. SanMedica International
854 F.3d 1088 (Ninth Circuit, 2017)
Navajo Nation v. Department of the Interior
876 F.3d 1144 (Ninth Circuit, 2017)
Franchise Tax Bd. of Cal. v. Hyatt
587 U.S. 230 (Supreme Court, 2019)
Ashley Judd v. Harvey Weinstein
967 F.3d 952 (Ninth Circuit, 2020)
Jennifer Christian v. Umpqua Bank
984 F.3d 801 (Ninth Circuit, 2020)
Nunies v. HIE Holdings, Inc.
908 F.3d 428 (Ninth Circuit, 2018)
Stephanie Sharp v. S&S Activewear, L.L.C.
69 F.4th 974 (Ninth Circuit, 2023)