In a victory for employers in wage and hour class actions, on August 11, 2022, the Nevada Supreme Court affirmed the grant of summary judgment in favor of HG Staffing, LLC and MEI-GSR Holdings, LLC, d/b/a Grand Sierra Resort. In Martel v. HG Staffing, LLC, the named representatives in the class action appeal were former employees of the Grand Sierra Resort who alleged violations of Nevada’s minimum wage and overtime laws. In a unanimous opinion, the Nevada Supreme Court affirmed the lower court’s decision and announced rulings on four issues of first impression regarding Nevada’s wage and hour laws.

First, the Nevada Supreme Court confirmed a two-year statute of limitations period applied to the wage claims at issue. Specifically, the former employees brought claims for violations of NRS 608.016 (pay for each hour worked), NRS 608.018 (overtime), and NRS 608.020 through NRS 608.050 (final paycheck statutes). The employer moved to dismiss as untimely the claims that accrued more than two years before the complaint was filed, and the district court dismissed the claims falling outside that limitations period. On appeal, the Nevada Supreme Court rejected the former employees’ arguments that their claims should instead be subject to a three-year limitations period under NRS 11.190(3)(a). The Nevada Supreme Court disagreed and applied the doctrine of analogous limitations first articulated in a 2016 decision, in which the court held that minimum wage claims brought under the...

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