James Ayers, et al. v. GKN Driveline North America, Inc.; John Carson, et al. v. GKN Driveline North America, Inc.; Tamika Ferges, et al. v. GKN Driveline North America, Inc.

CourtDistrict Court, M.D. North Carolina
DecidedOctober 23, 2025
Docket1:23-cv-00581
StatusUnknown

This text of James Ayers, et al. v. GKN Driveline North America, Inc.; John Carson, et al. v. GKN Driveline North America, Inc.; Tamika Ferges, et al. v. GKN Driveline North America, Inc. (James Ayers, et al. v. GKN Driveline North America, Inc.; John Carson, et al. v. GKN Driveline North America, Inc.; Tamika Ferges, et al. v. GKN Driveline North America, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Ayers, et al. v. GKN Driveline North America, Inc.; John Carson, et al. v. GKN Driveline North America, Inc.; Tamika Ferges, et al. v. GKN Driveline North America, Inc., (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

JAMES AYERS, et al., on behalf of ) themselves and all others similarly ) situated, ) Plaintiffs, ) ) v. ) 1:23-CV-581 ) GKN DRIVELINE NORTH ) AMERICA, INC., ) Defendant. ) --------------- JOHN CARSON, et al., on behalf of ) themselves and all others similarly ) situated, ) Plaintiffs, ) ) v. ) 1:23-CV-583 ) GKN DRIVELINE NORTH ) AMERICA, INC., ) Defendant. ) --------------- TAMIKA FERGES, et al., on behalf ) of themselves and all others similarly ) situated, ) Plaintiffs, ) v. ) 1:23-CV-585 ) GKN DRIVELINE NORTH ) AMERICA, INC., ) Defendant. )

MEMORANDUM OPINION AND ORDER

Catherine C. Eagles, Chief District Judge. The plaintiffs in these related actions are employees at plants operated by the defendant GKN Driveline North America in Mebane, Sanford, and Roxboro, North Carolina. They allege that GKN’s wage and hour policies violate the federal Fair Labor Standards Act and the North Carolina Wage and Hour Act. The plaintiffs now seek

collective certification for their FLSA actions and Rule 23 class certification for their NCWHA actions. On behalf of putative collective and class members, the plaintiffs have also moved to toll the statutes of limitations applicable to the FLSA collective and NCWHA class claims. The proposed pre-2020 subcollectives and subclasses are not suitable for collective and class resolution, and to that extent the motions for collective and class

certification will be denied. The Court lacks sufficient information to reach a conclusion as to the post-2020 subcollective and subclass, so the remainder of those motions will be held open. The motions for equitable tolling of the statutes of limitations will be granted for putative post-2020 class and collective members, back to the date these three actions were filed, pending further order on collective and class certification. Otherwise, the

motions for equitable tolling will be denied. I. Background Facts In 2018, employees and former employees of GKN filed suit alleging wage and hour violations under the FLSA and North Carolina law and seeking certification of an FLSA collective and a Rule 23 class. Mebane v. GKN, 18-CV-892.1 The Court

conditionally certified a collective and a class to seek relief based on GKN’s “policy of

1 To date there are 274 docket entries in Mebane. The Court has made no effort to provide a detailed summary of those proceedings, summarizing them here and elsewhere in this order only to the extent relevant and necessary. Going forward, all citations to proceedings in that case, 18- CV-892, will be cited as “Mebane, Doc. #.” rounding time.” Mebane, Doc. 82 at 24.2 A total of 384 employees opted-in to the FLSA action. Mebane, Doc. 271 at 2. The Court later certified an additional Rule 23 class

covering the plaintiffs’ NCWHA “auto-deduction” claims. Mebane, Doc. 154 at 2, 14. After more discovery, the Court decertified the classes and the collective. Mebane, Doc. 198.3 Some of the opt-in plaintiffs in Mebane then filed the three lawsuits now before the Court, one for each GKN plant in the Middle District. Ayers, 23-CV-581; Carson, 23-CV-583; Ferges, 23-CV-585.4 The complaints, as amended, include the same alleged violations as in Mebane, along with new violations based on changes GKN made

to its timekeeping policies in 2020. Doc. 34 at ¶¶ 48, 50.5 In each lawsuit, they sought certification of an FLSA collective and a Rule 23 class for the same pre-2020 “rounding” and “auto-deduction” FLSA and NCWHA violations alleged in Mebane and of an FLSA collective and a Rule 23 class for alleged violations beginning in 2020 after GKN changed its policies. Doc. 71 at 6–7; Doc. 73 at 8.

2 Mebane was handled by a different district judge, who has since moved to inactive senior status.

3 Much later, the named plaintiffs in Mebane settled with GKN, and that settlement was approved. Mebane, Doc. 266. Mr. Mebane has appealed the decertification order. Mebane, Doc. 272.

4 These three cases were initially overseen by the same judge who handled Mebane, until that judge moved to inactive senior status. The cases were reassigned to the undersigned judge on May 21, 2025. After a status conference with counsel, see Minute Entry 06/23/2025, the Court held all matters open at the request of the parties pending settlement discussions and a mediation. That proved unsuccessful, see Doc. 109, and the cases are now moving forward.

5 For convenience and unless otherwise noted, all CM/ECF Document citations are only to Ayers, 23-CV-581. Beyond the different plant locations, the pleadings and motions in all three cases do not meaningfully differ. Specifically, the plaintiffs request certification for three subcollectives and three subclasses: (1) a Pre-2020 Time-Shaving Subcollective/class, (2) a Pre-2020 30-Minute

Auto Deduction Subcollective/class, and (3) a Post-2020 Off-The-Clock Work Subcollective/class. Doc. 71 at 6–7; Doc. 73 at 8. The proposed subcollectives and subclasses mirror each other except for “look back” dates. Compare Doc. 71 at 6–7, with Doc. 73 at 8. On July 14, 2023, the same day the complaints were filed, the plaintiffs moved for equitable tolling of all FLSA and NCWHA claims for the named plaintiffs and any opt-in

plaintiffs.6 Doc. 8. On February 20, 2024, after briefing, the Court, per Magistrate Judge Auld, granted the motion for equitable tolling as to the named plaintiffs but denied it without prejudice as to any putative collective and class members. Doc. 45. The plaintiffs filed a new motion for equitable tolling on October 21, 2024. Doc. 85. In the motion, the plaintiffs request tolling for the “Opt-in Plaintiffs’ and the putative

class’s [FLSA] claims from the date Plaintiffs filed their consent to join forms in the . . . Mebane matter,” and the NCWHA claims “from October 23, 2018, the date the Mebane matter was filed.” Id. at 2. II. The Role of Discretion in Class Actions and FLSA Collective Actions Collective actions under 29 U.S.C. § 216(b) and class actions under Federal Rule

of Civil Procedure 23 are similar in some ways but have distinct and meaningfully

6 As of that date, no opt-in plaintiffs had filed consent forms in this case. Opt-in plaintiff consent forms were filed on various dates beginning on August 1, 2023, and ending on June 18, 2024. Docs. 13, 23 through 25, 27, 31 through 33, 43, 47, 61. different requirements. See generally Calderone v. Scott, 838 F.3d 1101, 1103–04 (11th Cir. 2016) (comparing FLSA collectives with Rule 23 classes); Waters v. Day &

Zimmerman NPS, Inc., 23 F.4th 84, 88–91 (1st Cir. 2022) (same); Hipp v. Liberty Nat’l Life Ins. Co., 252 F.3d 1208, 1216 (11th Cir. 2001) (same). Both can, among other benefits, provide more efficient ways to resolve large numbers of common or overlapping claims. See Calderone, 838 F.3d at 1103. But as the number of claimants multiplies, so too can the number of potential pitfalls. See generally Manual for Complex Litigation (Fourth) § 21 (2004). To head off

foreseeable complications and ensure the “just, speedy, and inexpensive determination” of such cases, Fed. R. Civ. P. 1, district courts must exercise significant discretion in certifying both collectives and class actions. See Hoffmann-La Roche Inc. v. Sperling, 493 U.S. 165

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