In 2017, the U.S. Supreme Court issued its ruling in Bristol-Myers Squibb (BMS), holding the Fourteenth Amendment prevents a state court from adjudicating nonresident plaintiffs’ state-law claims. Since then, various federal courts have considered whether that ruling extends to prevent a federal court from adjudicating claims brought under the federal Fair Labor Standards Act (FLSA) by individuals who live and work outside the court’s jurisdiction—and courts have come to vastly different conclusions. Savvy plaintiffs-side attorneys are leveraging this split to avoid bringing their FLSA collective action where the employer is located if that jurisdiction is deemed unfavorable, and instead identifying a putative plaintiff located in a “friendlier” jurisdiction that allows anyone with similar claims to opt-in, regardless of where they live or work.