Fortunately for employers, courts are beginning to restrict employees' ability to file collective actions. For example, the U.S. 6th Circuit Court of Appeals recently affirmed a district court's decision to “decertify” a collective action filed under the FLSA. The lawsuit involved a step-down nurse who challenged the employer's auto-deduction policies. Following his termination, the nurse alleged that his prior employer had violated the FLSA by failing to properly compensate him and other similarly situated employees for time worked during breaks. According to the nurse, his prior employer had failed to pay for missed and interrupted meal breaks at all three of its facilities.