Plaintiff’s Factual Allegations
Benjamin Folta sued Norfork Brewing Company and its owner, Jason B. Aamodt, under the Fair Labor Standards Act (FLSA). Folta’s employment at the brewery spanned from May 2018 to February 2021. His lawsuit centered on the allegation that Norfork and Aamodt failed to provide him with overtime compensation as required by the FLSA when he worked over forty hours per week. Before the district court, the primary issue was whether Folta qualified as a covered employee under the FLSA, which mandates minimum wage and overtime compensation for employees engaged in specific types of commerce or employment.
Arguments and Court Rulings
Before the district court, both parties filed motions for summary judgment. Norfork moved for summary judgment on the grounds that Folta was not a covered employee under the FLSA, contending that the Act requires compensation only for employees engaged in certain types of commerce or employment. The district court, however, found that there were genuine issues of material fact about this question and denied Norfork’s motion for summary judgment.
Conversely, Folta sought partial summary judgment, arguing that if he were indeed covered by the FLSA, then the undisputed facts shown his entitlement to overtime pay. The district court sided with Folta on this point, granting him partial summary judgment for entitlement to pay. But these decisions were not final and thus were not subject to appeal. As a result, the case remained open in the district court to resolve whether Folta was a covered employee under the FLSA.
After these court proceedings, the parties reached a settlement agreement. The district court found this agreement to be fair and reasonable, effectively resolving Folta’s FLSA claims. Folta was later awarded attorney’s fees in accordance with the FLSA statutes.
On appeal, Norfork challenged the earlier court decisions, contending that the district court lacked jurisdiction over the case. They argued that the determination of an employee’s coverage under the FLSA is fundamentally a jurisdictional issue. Folta countered by declaring the appeal moot due to the settlement and highlighted the absence of a final decision from the district court, which would preclude appellate jurisdiction.
The United States Court of Appeals for the Eighth Circuit reasoned that a case generally becomes moot when parties settle all their claims, as demonstrated by the resolution of all of Folta’s claims through the settlement. The court noted that Norfork’s assertion that the settlement agreement reserved their right to pursue a jurisdictional argument on appeal could not circumvent mootness. The language in the settlement did not conclusively reserve the right to appeal, and no final decision from the district court was available for appeal. The appeal was thus dismissed for lack of jurisdiction. The settlement between Folta and Norfork Brewing Company resolved all issues, leaving no live controversy or legally cognizable interest in the outcome for the appellate court to adjudicate.
Schrag on Law 