Summary Judgment Motions in Wage and Hour Class and Collective Actions: Pre- and Post-Certification Strategies

Disposing of or Limiting Claims, Improving Settlement Posture, Eliminating Class Members

Recording of a 90-minute CLE video webinar with Q&A

Conducted on Wednesday, September 29, 2021

Recorded event now available

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Course Materials

This CLE course will guide employment defense litigators on strategically pursuing summary judgment motions in wage and hour class and collective actions. The panel will discuss considerations and best practices for drafting and leveraging summary judgment motions both pre- and post-certification to dispose of or limit claims, eliminate putative class members, improve settlement posture, and more.


Wage and hour class and collective actions have the potential for costly discovery and exorbitant defense costs. As a result, defense counsel often pursues summary judgment motions as a strategy to defeat or limit claims early on, dismiss putative class members, or influence a potential settlement award.

Employment litigators must be strategic about the timing of summary judgment motions--before or after certification--and their interplay with decertification motions. Counsel must also approach the drafting of summary judgment motions strategically.

Listen as our authoritative panel of employment litigators examines how employment defense counsel strategically use summary judgment motions in wage and hour class and collective actions. In addition, the panel will discuss factors to consider when weighing whether to file summary judgment motions pre- or post-certification.



  1. Summary judgment motions pre-certification
    1. Purpose/goal
    2. Strategic considerations
  2. Summary judgment motions post-certification
    1. Purpose/goal
    2. Strategic considerations


The panel will review these and other key issues:

  • What are the benefits of making summary judgment motions pre-certification?
  • Under what circumstances should post-certification summary judgment motions be made?
  • What are some best practices for drafting summary judgment motions in wage and hour class and collective actions?


Cripps, Jesse
Jesse A. Cripps

Gibson Dunn & Crutcher

Mr. Cripps handles the full range of labor and employment matters under federal and state law, specializing in the...  |  Read More

Nunn, Todd
Todd L. Nunn

K&L Gates

Mr. Nunn's practice emphasizes employment law, class action defense and electronic discovery. He has defended...  |  Read More

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