Tripp v. Perdue Foods LLC

CourtDistrict Court, D. Maryland
DecidedApril 22, 2025
Docket1:24-cv-00987
StatusUnknown

This text of Tripp v. Perdue Foods LLC (Tripp v. Perdue Foods LLC) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tripp v. Perdue Foods LLC, (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

BARBARA TRIPP, individually and on Behalf of all others similarly situated, *

Plaintiff, *

v. * Civil Case No. 1:24-CV-00987-JMC

PERDUE FOODS, LLC, *

Defendant. *

* * * * * * * * MEMORANDUM OPINION AND ORDER Plaintiff Barbara Tripp, on behalf of herself and all others similarly situated, filed the present lawsuit against Defendant, Perdue Foods LLC, alleging violations of the Fair Labor Standards Act (FLSA) and seeking declaratory judgment under the Federal Declaratory Judgment Act. (ECF No. 1). This Court granted in part Ms. Tripp’s Motion for Conditional Certification and to Facilitate Notice Pursuant to 29 U.S.C. § 216(b) on November 13, 2024 conditionally certifying the proposed collective. (ECF No. 34). On November 22, 2024, the parties jointly submitted a Rule 26(f) Report, proposing that they provide the Court with a discovery plan within fourteen days of the close of the collective action opt-in period. (ECF No. 36). The undersigned approved the parties’ proposal on November 25, 2024, and pursuant to that Order, the parties submitted a Supplemental Joint Rule 26(f) Report (“Supplemental Rule 26(f) Report”) on April 17, 2025. (ECF No. 70). The opt-in period closed on April 3, 2025 and, at present, it appears that eighty (80) Plaintiffs have opted-in to this action. In the Supplemental Rule 26(f) Report, the parties identify points of disagreement and provide an overview of their respective positions regarding how discovery should proceed going forward. The Court resolves disputes between the parties as set forth immediately below. Discovery Deadline: All fact discovery and decertification expert discovery shall be completed on or before April 6, 2026.1 The parties may request time to conduct additional expert discovery following the Court’s ruling on Defendant’s decertification motion.

Subjects of Discovery: The parties include a list of subjects they anticipate they will need discovery on, including: • Whether Plaintiffs are “similarly situated;” • Whether a collective action is appropriate; • Whether Plaintiffs are independent contractors or employees under the economic realities test; • Whether Plaintiffs are otherwise exempt under the FLSA; • Whether Defendant acted in good faith; • Whether Defendant’s acts were willful; • Hours worked by Plaintiffs; • Whether Defendant knew or should have known of the hours worked by Plaintiffs; • Whether hours worked by Plaintiffs were compensable; • Any defenses raised by Defendant, as set forth in its answer or that becomes otherwise applicable as discovery proceeds; • Other facts that affect or are relevant to Plaintiffs[’] claims and/or Defendant’s defenses; • The amount of damages to which Plaintiffs are entitled, if any; • Defendant’s company policy, pattern, or practice, related to how Defendant classified Plaintiffs; • The total compensation Defendant paid Plaintiffs; and • Any previous or ongoing complaints filed with or investigations by the United States Department of Labor and/or state agencies into Defendant’s pay practices.

(ECF No. 70 at 2-3). The Court approves this list of subjects, notwithstanding the parties’ right to seek a protective order or other relief in response to specific requests which they deem objectionable. Written Discovery: The parties agree on the scope of written discovery between the Named Plaintiff and Defendant, and propose the following: they may each serve a maximum of thirty (30)

1 The parties have agreed to this deadline. (ECF No. 70 at 2). interrogatories and thirty (30) requests for production of documents on one other, with responses and objections due thirty (30) days after service, except as otherwise consented to by the parties. Id. at 3. Regardless of consent, the parties may also motion the Court for an extension time to respond to discovery requests. Id. The parties will adhere to Rule 36 of the Federal Rules of Civil

Procedure concerning any requests for admission. Id. The Court approves and adopts the written discovery plan proposed between the Named Plaintiff and Defendant. The parties were unable to reach an agreement regarding written discovery served on opt- in Plaintiffs and therefore provide competing proposals. Id. Plaintiffs request that written discovery be limited to 10% of the total opt-in Plaintiff class and propose that Defendant be permitted to serve five (5) interrogatories and five (5) requests for production of documents on each opt-in Plaintiff, with each opt-in Plaintiff subject to discovery having the ability to serve the same number

of written discovery requests on Defendant. Id. at 4. Plaintiffs further suggest that the parties jointly select which members of the opt-in Plaintiff class will be subject to written discovery, with Defendant selecting half and Plaintiffs selecting the other half. Id. Defendant seeks written discovery from all opt-in Plaintiffs and requests it be permitted to serve a maximum of eight (8) interrogatories and eight (8) requests for production of documents, each including discrete subparts, on every opt-in Plaintiff. Id. at 8. Defendant notes that the written

discovery served on each opt-in Plaintiff would be substantially identical. Id. Additionally, Defendant opposes Plaintiff’s request that each opt-in Plaintiff be permitted to propound written discovery on Defendant, but asks that if the Court deems it appropriate, any written discovery served by the opt-in Plaintiffs be substantially identical. Id. at 12. As observed by Judge James K. Bredar of this Court, “[f]ederal courts are divided when it comes to individualized discovery in opt-in classes.” Jones v. Hoffberger Moving Servs. LLC, No. 13-cv-0535-JKB, 2014 WL 713541, at *1 (D. Md. Feb. 24, 2014). Two approaches to discovery in FLSA actions have emerged, “with plaintiffs often seeking to engage in limited representative discovery, and defendants urging courts to require more expansive individualized discovery.” Craig v. Rite Aid Corp., No. 4:08-CV-2317, 2011 WL 9686065, at *3 (M.D. Penn. Feb 7, 2011).

Many district courts have held that individualized discovery is overly burdensome and does not comport with the FLSA’s underlying rationale in permitting such cases to proceed as collective actions. Id. (collecting cases).2 Other courts have reached the opposite conclusion, reasoning that because collective members have opted in to the action, they are appropriately treated as “ordinary party plaintiffs who are subject to the full range of discovery that is authorized by the Federal Rules of Civil Procedure.” Id. (collecting cases). This division is further reflected in the Supplemental Rule 26(f) Report, as both parties cite a plethora of cases in support of their respective positions. (ECF No. 70 at 5-11).

The Court recognizes Defendant’s need to gather adequate information to prepare its eventual motion for decertification, but is not persuaded this requires individualized discovery from each opt-in Plaintiff. Instead, the undersigned believes that a middle ground between the parties’ two proposals will best balance Defendant’s ability to establish its defenses while maintaining an efficient process. Representative discovery is appropriate in this case, particularly given the fact that Plaintiffs were all classified as independent contractors under the Poultry Producer Agreement, which sets forth the same rules and policies for each of them. See Jones, 2014 WL 713541, at *2 (“Where, as here, the factual dispute between the parties focuses on an

employer’s policies and practices, limiting discovery to a representative sample of Opt-In Plaintiffs

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Bluebook (online)
Tripp v. Perdue Foods LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tripp-v-perdue-foods-llc-mdd-2025.