Seventh Circuit Joins Third, Sixth, and Eighth Circuits in Limiting Exercise of Personal Jurisdiction in FLSA Collective Actions
On August 16, 2024, the Seventh Circuit Court of Appeals weighed in on whether out-of-state plaintiffs must satisfy personal jurisdiction requirements to participate in a collective action under the Fair Labor Standards Act (FLSA). In a 2–1 decision, the Seventh Circuit held they must, joining the Third, Sixth, and Eighth Circuit Courts of Appeals and rejecting the First Circuit Court of Appeals’ position. Smooth ionic columns holding a ceiling seen from a low perspective backed by a blue sky with fluffy clouds Quick Hits On August 16, 2024, the Seventh Circuit held that opt-in plaintiffs must each satisfy personal jurisdiction requirements to participate in FLSA collective actions. The Seventh Circuit joined the Third, Sixth, and Eighth Circuits and rejected the First Circuit’s ruling on personal jurisdiction with respect to the claims of prospective opt-in plaintiffs in FLSA collective actions. The Seventh Circuit held that “a court must establish its jurisdiction over claims one at ...