Employer-Employee-Fair Labor Standards Act-Overtime-Sufficiency of Pleadings

Staff Report//January 29, 2026//

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Defendant moved to dismiss plaintiff’s complaint. Plaintiff alleged violations of the Fair Labor Standards Act for failure to pay overtime in a postbaccalaureate research program. In support of its motion, defendant argued that plaintiff failed to plead an employer-employee relationship and failed to adequately plead an overtime claim,. Plaintiff cross-moved to conditionally certify a collective action in her FLSA claim.

Where defendant expressly designated program workers as full-time, non-exempt employees, the lack of discovery on other factors weighing on whether the parties had an employer-employee relationship precluded dismissal of plaintiff’s individual FLSA claim, but plaintiff failed to show that other workers suffered overtime violations or that she was similarly situated to other workers.

Defendant’s motion to dismiss denied in part and granted in part.

Flowers v. The Washington University (MLW No. 84282/Case No. 4:24-CV-1504-ZMB – 9 pages) (U.S. District Court, Eastern District of Missouri, Bluestone, J.)