Sixth Circuit reinforces role of juries in determining employer intent under FLSA
In Su v. KDE Equine, LLC, the Sixth Circuit Court of Appeals vacated a summary judgment ruling that had dismissed claims under the Fair Labor Standards Act (FLSA) and sent the case back for trial. At issue was whether KDE Equine, a horse-training company, had willfully violated the FLSA in its overtime pay practices. The appellate court emphasized that disputes over KDE’s intent could not be resolved at the summary judgment stage, as they involved credibility assessments and subjective determinations that require resolution by a jury.
The court specifically underscored the importance of a jury in cases where questions of intent and state of mind are central. The judges noted that determining whether KDE knowingly or recklessly disregarded risks of FLSA noncompliance involves factual inferences and evaluations of credibility that are not appropriate for summary judgment. The ruling rejected the district court’s reliance on credibility assessments made during a prior bench trial on related but distinct issues, reinforcing the need for a full trial to address the willfulness question.
North Carolina Supreme Court addresses jury voir dire in civil cases
In a case of first impression, the North Carolina Supreme Court ruled on the trial court’s authority to reopen jury voir dire in civil cases after a jury has been impaneled. In Warren v. Bonner, the court vacated a trial court judgment that allowed defendants to exercise a peremptory challenge on a juror after the trial had commenced. The ruling centered on whether statutes governing jury selection in civil cases authorize such actions.
The trial court had impaneled the jury and begun proceedings when defendants raised concerns about a juror’s connection to the plaintiffs. Upon inquiry, the trial court found no cause to remove the juror but permitted defendants to exercise a peremptory challenge to strike the juror, replacing the juror with an alternate. This decision was based on the trial court’s interpretation of statutory discretion and analogies to criminal case procedures under N.C. Gen. Stat. § 15A-1214.
The supreme court, however, concluded that existing statutes governing civil jury selection (N.C. Gen. Stat. § 9-19) do not permit peremptory challenges once the jury is impaneled. While the trial court retains discretion to reopen voir dire to address potential bias, it cannot authorize peremptory challenges after the jurors have been accepted. The court emphasized the materiality and fairness of adhering to established jury selection rules and rejected the application of criminal procedural standards to civil cases.
Alabama Supreme Court exempts nursing mothers from jury duty
The Alabama Supreme Court has issued a significant administrative order granting nursing mothers the ability to be excused from jury duty without appearing in person. Effective January 17, 2025, the order ensures that nursing mothers of infant children can request an exemption in advance of their jury summons date, alleviating the need to appear in court to apply for the excuse.
This decision comes after reports of breastfeeding mothers facing difficulties obtaining exemptions, despite contacting court officials and submitting forms. The court’s directive requires presiding circuit judges across the state to implement procedures allowing nursing mothers to request exemptions through phone, email, or written communication before their summoned date. Circuit judges have been given 30 days to ensure these procedures are in place.
High-profile trial begins for A$AP Rocky on firearm charges
Jury selection is underway in the high-profile trial of Grammy-nominated rapper A$AP Rocky, who faces two felony counts of assault with a semiautomatic firearm. The charges stem from allegations that the artist fired a gun at his former friend, Terell Ephron, during an altercation in Hollywood in November 2021. Ephron testified that bullets grazed his knuckles, and if convicted, Rocky could face up to 24 years in prison.
The case has drawn significant public attention due to Rocky's status as a hip-hop star, fashion icon, and actor, as well as his high-profile relationship with Rihanna. Superior Court Judge Mark Arnold emphasized fairness during jury selection, stating that all defendants are to be treated equally under the law. Cameras will be permitted in the courtroom for the duration of the trial.
Opening statements are expected as soon as Wednesday, with the trial serving as a critical legal battle for the artist, whose career includes an upcoming Spike Lee film and a role as a celebrity chair for the Met Gala. A$AP Rocky has pleaded not guilty, and his attorney maintains that he committed no crime.
The National Center for State Courts and the Center for Jury Studies have developed tools to assist courts with high-profile cases. For more information visit High-Profile Cases.
Governor JB Pritzker reports for jury duty in Chicago
ABC7 Chicago reports Illinois Governor JB Pritzker joined fellow citizens in the democratic process by reporting for jury duty at the George N. Leighton Criminal Courthouse in Chicago. Sharing his experience on social media, the governor called it an honor to participate and thanked others for fulfilling their civic duty on a chilly January day.
Pritzker arrived at the courthouse early Wednesday morning and spent several hours awaiting the jury selection process. While he was not ultimately selected to serve on a jury, the governor's participation highlights the importance of jury duty as a cornerstone of democracy.