Key Takeaways:

• The Fourth Circuit held that employees that settled and released their individual claims after the District Court decertified the class and collective actions had waived their claims and, thus, lacked standing to bring an appeal.
• This decision was made despite the language of the settlement agreement attempting to carve out a right to appeal – emphasizing the importance of well-crafted release language in wage and hour cases.

On June 2, 2026, the U.S. Court of Appeals for the Fourth Circuit issued a unanimous decision addressing the question of whether an employee who settled his individual wage-and-hour claims with his employer has standing to challenge a district court’s decertification of a class and collective action which occurred prior to that settlement. The Court answered in the negative.

In Mebane v. GKN Driveline North America, Inc., 4th Cir., No. 25-02191, a three-judge panel in the Fourth Circuit unanimously dismissed an appeal filed by former auto parts workers holding that they lacked standing to bring the appeal. Mebane and another auto worker, Angela Worsham, had sued their employer, GKN, in 2018, alleging that GKN violated both the Fair Labor Standards Act (the “FLSA”) and the North Carolina Wage and Hour Act (the “NCWHA”) by rounding work time and automatically deducting meal breaks. A North Carolina district court initially certified two Rule 23 classes and a FLSA collective, but later decertified them after determining that the alleged...

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