Wage and hour class action procedure
GKN workers lose bid to revive unpaid overtime claims after settlement
The Fourth Circuit said James Mebane gave up his personal stake when he settled his own claims, so he could not keep pressing the challenge to class decertification. The court did not decide whether GKN’s pay practices violated federal or North Carolina wage law.
The Fourth Circuit dismissed James Mebane’s appeal in a wage case against GKN Driveline North America after he settled his own claims. That ended the effort to revive class claims over alleged unpaid overtime and wages. The court did not reach the merits of the pay dispute.
- The Fourth Circuit dismissed James Mebane’s wage appeal.
- Workers had alleged unpaid overtime and wages under federal and North Carolina law.
- Mebane settled his individual claims before filing the appeal.
- The court did not rule on whether GKN broke wage laws.
- Workers at GKN Driveline North America lost the chance to keep a wage case alive in the Fourth Circuit, which on June 2, 2026, dismissed James Mebane’s appeal from a Middle District of North Carolina ruling
Workers at GKN Driveline North America lost the chance to keep a wage case alive in the Fourth Circuit, which on June 2, 2026, dismissed James Mebane’s appeal from a Middle District of North Carolina ruling. The suit said GKN’s time-rounding and automatic meal-break deductions left employees short on overtime pay and wages.
Mebane and Angela Worsham sued on behalf of themselves and other similarly situated workers under the Fair Labor Standards Act, or FLSA, and the North Carolina Wage and Hour Act, or NCWHA. At one point, the district court had certified two classes and conditionally certified an FLSA collective action.
The settlement that cut off the fight
The judges said Mebane settled his individual claims before he filed the notice of appeal. Once he gave up the underlying wage dispute, they said, he no longer had the live personal stake needed to challenge the decertification order.
The court said a plaintiff can sometimes keep fighting over class representation even after losing the personal claim, but not after voluntarily settling away the case itself. A settlement clause reserving the right to appeal did not change that result.
No ruling on the pay practices
Because the appeal was dismissed, the court did not reach whether GKN’s pay practices violated federal or North Carolina wage law. The decision leaves workers without this appellate route to recover alleged back pay through a class case.