Court: Voicing disagreement with pay practices on Facebook isn't enough to constitute protected FLSA activity

I love employment law and social media, so I read with interest Morse v. JP Morgan Chase & Co., an opinion from the Middle District of Florida. Plaintiff claims the defendant terminated her from employment for voicing disagreement with its pay practices. But where did she voice this disagreement? Her Facebook page. The court granted the defendant's motion to dismiss, quoting the U.S. Supreme Court's recent decision in Kasten v. Saint-Gobain Performance Plastics Corp. (see my blog on that case) that protected activity for purposes of the Fair Labor Standards Act's anti-retaliation provision requires an employee complaint to have "some degree of formality, certainly to the point where the recipient has been given fair notice that a grievance has been lodged and does, or should, reasonably understand the matter as part of its business concerns." Facebook did not meet this standard.