The Application of Bristol-Myers to FLSA Collective Actions

April 16, 2025  |  New York Law Journal

Southern District Judge Kenneth M. Karas’s recent decision in Schiller-Egles v. PromptCare Companies, Inc. adds to the growing consensus that the Supreme Court’s 2017 Bristol-Myers decision applies to FLSA collective actions. Judge Karas held that the Southern District of New York lacked personal jurisdiction over out-of-state opt-in plaintiffs whose claims had no connection to New York, aligning with multiple circuit courts that have extended Bristol-Myers beyond state court mass torts. In their latest article for the New York Law Journal, “The Application of Bristol-Myers to FLSA Collective Actions,” Morvillo Abramowitz Grand Iason & Anello PC partners Edward M. Spiro and Christopher B. Harwood examine how the Southern District interpreted and applied Bristol-Myers to FLSA collective actions, emphasizing the evolving standards for personal jurisdiction over opt-in plaintiffs in federal wage-and-hour litigation.

The Application of Bristol-Myers to FLSA Collective Actions