Motion for Summary Judgment: Rodriguez v. MSU

Memorandum of Points and Authorities in Support of Defendant's Motion for Summary Judgment — addressing FLSA student-employee classification and False Claims Act retaliation under 31 U.S.C. § 3730(h).

This brief argues that Defendant Meridian State University is entitled to summary judgment on three independent grounds: (1) Plaintiff was a student, not a covered FLSA employee, under the Glatt primary beneficiary test; (2) Plaintiff did not engage in protected activity placing MSU on notice of alleged federal fraud; and (3) Plaintiff cannot establish but-for causation given MSU's pre-existing, budget-driven restructuring.

Key authorities include Glatt v. Fox Searchlight Pictures, Inc., 811 F.3d 528 (2d Cir. 2016); Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986); and Celotex Corp. v. Catrett, 477 U.S. 317 (1986).

Motion for Summary Judgment: Rodriguez v. Meridian State University