Lobo v. Sprint Safety, Inc.

District Court, S.D. Texas·Decided July 2, 2020·No. 4:19-cv-03934·Unknown

Opinion

□ Southern District of Texas ENTERED IN THE UNITED STATES DISTRICT COURT uy a FOR THE SOUTHERN DISTRICT OF TEXAS mee EIS HOUSTON DIVISION MANUEL LOBO, Individually andon § Behalf of All Others Similarly Situated, § Plaintiff, § § V. § CASE NO. 4:19-CV-3934 § SPRINT SAFETY, INC., § Defendant. §# MEMORANDUM AND ORDER Before the Court in this Fair Labor Standards Act (“FLSA”) overtime case is Plaintiff Manuel Lobo’s (“Plaintiffs”) Motion for Class Certification and Expedited Discovery [Doc. # 36] (“Motion”). Defendant Sprint Safety, Inc. (“Defendant”) has responded,' Plaintiff has replied,” and Defendant has filed a sur-reply.*_ The Motion is ripe for decision. Based on the parties’ briefing, pertinent matters of record, and relevant legal authorities, the Court grants in part and denies in part Plaintiffs Motion.

Opposition to Plaintiff’s Motion for Class Certification and Expedited Discovery [Doc. # 37] (“Defendant’s Response’). Plaintiff Manuel Lobo’s Reply in Support of his Opposed Motion for Class Certification & Expedited Discovery [Doc. # 40] (“Plaintiff's Reply”). 3 Sprint Safety’s Sur-Reply in Response to Plaintiff's Reply in Support of Motion for Class Certification and Expedited Discovery [Doc. # 41-1] (“Defendant’s Sur- Reply”).

I. BACKGROUND The following factual summary is based on evidence attached to Plaintiff’s

Motion, Defendant’s Response, and facts admitted in Defendant’s Answer to Plaintiff’s Complaint. Defendant provided industrial safety equipment and services to energy industrial plants.4 Defendant sold and rented safety equipment on site at industrial

plants undergoing maintenance, upgrades, or repairs, also called “turnarounds.”5 Defendant is a Delaware corporation with offices in Houston.6 Defendant employs Turnaround Technicians (“Putative Class Members”) to stock shelves with rental

equipment and personal protective equipment, assist with inventory count, inspect, test and maintain safety equipment, and issue and receive rental equipment.7 Plaintiff worked for Defendant as a Turnaround Technician from approximately January 2016 until June 2018.8 As a Turnaround Technician,

4 Exhibit 1 to Defendant’s Response, Declaration of Thomas Heslin (“Heslin Decl.”), [Doc. # 37-1] ¶ 5. 5 Id. ¶ 6. 6 Defendant’s Answer and Affirmative Defenses to Plaintiff’s Original Complaint (“Defendant’s Answer”) [Doc. # 35] ¶¶ 7, 9. 7 Heslin Decl. ¶¶ 5-7; Lobo Decl. ¶ 9. 8 Defendant’s Answer ¶ 14; Exhibit A to Plaintiff’s Motion, Declaration of Manuel Lobo (“Lobo Decl.”), [Doc. # 36-1] ¶2. Plaintiff was required to work 12 hour-shifts, was classified as non-exempt, and was paid overtime.9 During his employment with Defendant, Plaintiff worked on at least

seven different turnaround projects at different plants with different supervisors.10 Turnaround Technicians were subject to a meal break policy which automatically deducted thirty minutes from every worker on every shift for meals, regardless of whether they took a thirty-minute uninterrupted meal break.11 Plaintiff

and other Turnaround Technicians never clocked out or in for uninterrupted meal breaks because they were not allowed uninterrupted meal breaks.12 Plaintiff claims that he and other Turnaround Technicians were instructed by

their supervisors not to leave their posts for lunch breaks.13 Rather than take their lunch break at a “lunch tent” on the jobsite, Plaintiff claims he and other Turnaround

9 Lobo Decl. ¶ 9; Exhibit B to Plaintiff’s Motion, Turnaround Technician Job Description, [Doc. # 36-2]. 10 Lobo Decl. ¶ 5 11 Lobo Decl. ¶ 15; Exhibit C to Plaintiff’s Motion, Weekly Time Records & Pay Statements, [Doc. # 36-3]; Exhibit D to Plaintiff’s Motion, Sprint Safety’s Employee Handbook, [Doc. # 36-4] at 27; Exhibit H to Plaintiff’s Motion, Declaration of Marshae Essett (“Essett Decl.”), [Doc # 36-8] ¶¶ 7-8. 12 Lobo Decl. ¶¶ 17-22; Essett Decl. ¶¶ 7-8. 13 Lobo Decl. ¶¶ 19-20; Essett Decl. ¶¶ 7-8. Technicians were instructed by their supervisors to eat lunch at their posts so they could be available to work during their lunch breaks.14

Plaintiff does not recall a single day during his three years of employment with Defendant when he was able to take an uninterrupted 30-minute lunch break.15 When Plaintiff attempted to take meal breaks at his post, he claims that he was

almost always interrupted by Defendant’s employees or other workers on the jobsite that needed equipment.16 Plaintiff was required to be available at all times and was not allowed to turn anyone away during his lunch break.17 Plaintiff also claims that even though Defendant was aware his and other

Turnaround Technicians’ meal breaks were often interrupted or not taken at all, Defendant would automatically deduct thirty minutes from their shifts.18 Plaintiff and other Turnaround Technicians could avoid the automatic meal

break deduction by correcting their time records and having their supervisors

14 Lobo Decl. ¶ 21. 15 Id. ¶ 18. 16 Id. ¶ 19. 17 Id. ¶¶ 19-20. 18 Id. ¶ 17. approve the change.19 Plaintiff claims that correcting one’s time records presents logistical issues and impermissibly shifts the burden of recordkeeping from the

employer to the employee.20 In 2015, following an investigation, the U.S. Department of Labor (“DOL”) found Defendant in violation of the FLSA for its automatic lunch break deduction policy.21 The DOL determined that Defendant failed to pay proper wages to 37

employees as a result of the automatic deduction.22 Following the DOL investigation and findings, Defendant agreed to correct the problem going forward.23 Plaintiff argues that Defendant never corrected the problem and continues to automatically

deduct meal breaks in violation of the FLSA.24

19 Exhibit C to Plaintiff’s Motion, Weekly Time Records & Pay Statements, [Doc. # 36-3]; Exhibit D to Plaintiff’s Motion, Sprint Safety’s Employee Handbook, [Doc. # 36-4] at 27. 20 Motion at 10. 21 Exhibit E to Plaintiff’s Motion, U.S. DOL Records, Case ID: 1773727, [Doc. # 36-5] at 4. 22 Id. at 3-4. 23 Id. at 5. 24 Motion at 9. Plaintiff seeks conditional certification of this case as a collective action. Plaintiff requests that the Court conditionally certify a putative class of:

All Turnaround Technicians who were subject to Sprint Safety’s automatic meal break deduction within the last three years.25 II. LEGAL STANDARD Section 216(b) of the FLSA provides a private right of action for employees against employers who violate the Act. Similarly situated employees may “opt-in” to a suit under § 207(a) and proceed as a collective. “Courts recognize two methods

for determining whether to certify a collective action on a conditional basis or authorize notice to similarly situated employees: the spurious class action Shushan approach, or the two-step Lusardi approach.” Hernandez v. Helix Energy Solutions Grp., Inc., No. H-18-1588, 2018 WL 6067293, at *2 (S.D. Tex. Nov. 20, 2018)

(Rosenthal, J.). The Fifth Circuit has not determined which method is more appropriate, but district courts in the Fifth Circuit “have uniformly used [the Lusardi approach] to determine whether a collective [action] should be certified under the

FLSA.” Johnson v. Big Lots Stores, Inc., No. 04-3201, 2007 WL 5200224, at *3 (E.D. La. Aug. 21, 2007); see also Acevedo v. Allsup’s Convenience Stores, Inc.,

25 Motion at 2. Plaintiff’s Motion also contains numerous allegations that he and other Putative Class Members were required to use pre-filled time sheets that underreported their hours worked. See Lobo Decl. ¶¶11-13. Because Plaintiff’s proposed class only relates to Defendant’s automatic meal break deduction policy, allegations related to inaccurate shift start and end times are not discussed in this Order.

Lobo v. Sprint Safety, Inc., (S.D. Tex. 2020).

Lobo v. Sprint Safety, Inc. (Lobo v. Sprint Safety, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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