Employees and former employees at three North Carolina manufacturing plants sued GKN under the Fair Labor Standards Act and the North Carolina Wage and Hour Act, alleging that timekeeping policies forced them to work without compensation before shifts, after shifts, and during meal breaks.
The lawsuits are a continuation of predecessor litigation filed in 2018, Mebane v. GKN Driveline N. Am., Inc., which involved similar claims regarding rounding time and auto-deductions for meal breaks. That earlier case resulted in conditional certification, subsequent decertification after discovery revealed individual issues would swamp class-wide resolution, and a settlement for the named plaintiffs.
Following that history, plaintiffs filed three new cases—one for each facility in Alamance, Sanford, and Roxboro—seeking certification of FLSA collectives and Rule 23 classes for violations occurring after GKN changed its timekeeping policies in 2020.
Judge Eagles denied the motions, emphasizing that wage-and-hour class actions require concrete plans for managing liability and damages rather than vague references to representative proof. The court noted that the proposed classes covered at least six different forms of alleged off-the-clock work across three facilities, creating significant manageability problems.
The court held that plaintiffs failed to explain how they would efficiently prove liability for each employee or address individual damages, which vary based on time actually worked. The judge also criticized plaintiffs' counsel for a lack of organization, citing omitted claims and inaccurate factual representations in their briefing.
Because the plaintiffs did not show that common issues predominate or that a class action is superior to other adjudication methods, the motions for both Rule 23 class certification and FLSA collective certification were denied.