The U.S. Court of Appeals for the Fourth Circuit affirmed a district court ruling favoring Butterball, LLC in a wage and hour dispute with employee Osvaldo Figueroa, according to a published opinion issued Jan. 13, 2026.
The three-judge panel unanimously upheld the U.S. District Court for the Eastern District of North Carolina's decision in *Figueroa v. Butterball, LLC* (4th Cir. 2026). Judge Deandrea Gist Benjamin wrote the opinion, joined by Judges Richardson and Rushing.
Figueroa filed suit on behalf of himself and others similarly situated against the turkey producer, seeking unpaid wages under both the North Carolina Wage and Hour Act and the Fair Labor Standards Act. The case centered on whether Butterball properly compensated its turkey loaders for their work.
The district court initially dismissed the North Carolina state law claims before granting summary judgment in favor of Butterball on the federal FLSA claim. A key factor in the lower court's decision was its determination that Figueroa worked as a piece-rate employee rather than an hourly employee.
Piece-rate compensation systems pay workers based on the amount of work completed or units produced, rather than for time spent on the job. This classification can significantly affect how overtime and minimum wage requirements apply under federal labor law.
The district court found that this employment classification meant Butterball did not violate wage and hour laws in its compensation of turkey loaders. The Fourth Circuit agreed, affirming the lower court's analysis and conclusions.
Judge Benjamin opened the appellate opinion with a lighthearted observation about turkey disputes, writing, "Disputes over turkey typically happen in late November and involve who gets a better portion of the meat. This is not that."
The case was argued before the appellate panel on Sept. 9, 2025, and the court issued its published decision roughly four months later. Published opinions carry precedential weight and can influence future employment law cases within the Fourth Circuit's jurisdiction.
Figueroa was represented by Gilda Adriana Hernandez of the Law Offices of Gilda A. Hernandez, PLLC in Cary, North Carolina. Also appearing on brief were Matthew S. Marlowe and Hannah B. Simmons from the same firm.
Butterball was represented by Scott David Anderson of Womble Bond Dickinson (US) LLP in Raleigh, North Carolina. Hayden J. Silver III, also from Womble Bond Dickinson, appeared on the company's brief.
The original case was filed in 2020 before District Judge James C. Dever III in the Eastern District of North Carolina at Raleigh. The matter proceeded through discovery and motion practice before reaching the summary judgment stage that ultimately resolved the case in Butterball's favor.
The Fourth Circuit's jurisdiction covers federal appeals from district courts in Maryland, North Carolina, South Carolina, Virginia, and West Virginia. Employment law cases involving wage and hour disputes regularly come before the court, making this decision potentially significant for future workplace compensation cases in the region.
The distinction between piece-rate and hourly compensation has become increasingly important as employers seek different ways to structure worker pay. The classification can affect everything from overtime calculations to minimum wage compliance under both federal and state labor laws.
Under the FLSA, piece-rate employees are still entitled to minimum wage protections and overtime pay when they work more than 40 hours per week. However, the calculations for determining compliance can be more complex than with traditional hourly workers.
The North Carolina Wage and Hour Act provides additional worker protections at the state level, though the district court found those claims lacking in this case. The dismissal of the state law claims was not the subject of Figueroa's appeal to the Fourth Circuit.
Butterball is one of the largest turkey producers in the United States, with processing facilities across multiple states. The company's operations rely heavily on production workers who handle various aspects of poultry processing, including the turkey loading positions at issue in this case.
The case highlights ongoing challenges in employment law around proper worker classification and compensation structures. As companies continue to use various pay systems, courts must analyze whether those arrangements comply with federal and state wage and hour requirements.
The Fourth Circuit's affirmance means the district court's ruling in favor of Butterball stands. The published nature of the opinion ensures it will serve as binding precedent for future cases involving similar wage and hour issues within the circuit.