Vanegas v. Signet Builders, Inc.

In a successive appeal in a matter where an employee filed a lawsuit against his employer under the Fair Labor Standards Act, the Seventh Circuit considered two issues: 1) do FLSA collective actions require personal jurisdiction only over their representative plaintiffs, and 2) does FRCP 4 create a “backdoor” way to exercise nationwide personal jurisdiction in FLSA cases. The Seventh Circuit answered both questions in the negative, finding that a court overseeing a collective action must secure personal jurisdiction over each plaintiff’s claim, whether representative or opt-in, individually. (PRYOR, concurring and ROVNER, dissenting)