Barton v. House of Raeford Farms, Nos. 12-1943 and 12-1945 - 12-1946, 2014 U.S. App. LEXIS 4500 (4th Cir. Mar. 11, 2014)

(current and former employees of a chicken processing company filed claims  against the company, seeking payment of unpaid wages allegedly withheld in violation of the South Carolina Payment of Wages Act (SCPWA) and damages for retaliation against them for instituting workers' compensation proceedings;  a jury returned a verdict in favor of 16 employees on the SCPWA claims, and the trial court in a bench trial found in favor of 8 employees on the retaliation claims; on appeal, the Fourth Circuit reversed the jury award on the SCPWA claims, concluding that they were preempted by § 301 of the Labor Management Relations Act ("LMRA") because the claims involved an alleged failure by the company to properly count the employees’ hours as required by the collective bargaining agreement; the court also reversed the judgment on the retaliation claims as to six employees, finding that they failed to present evidence sufficient to show that they had “instituted” workers’ compensation claims; the court affirmed as to the remaining two employees’ retaliation claims).