Hamelin v. Faxton-St. Luke's Healthcare
2011 U.S. Dist. LEXIS 56923
N.D.N.Y.2011Background
- Plaintiffs sued Faxton-St. Luke’s Healthcare and related entities for FLSA, ERISA, and NYLL violations based on unpaid meal breaks, pre/post-shift work, and improper overtime calculations.
- Defendants moved to dismiss eight opt-in plaintiffs under Rule 56, arguing they did not pursue claims within the certified class definitions.
- The court had previously conditionally certified a 2,668-member FLSA class and later addressed eligibility of 149 opt-ins already in the action.
- Disputed plaintiffs answered interrogatories denying they worked through meals; one plaintiff, Lohnas, later affirmed a memory-based change subject to records, but still largely maintained no unpaid meal work.
- The court considered four alleged policies: automatic 30-minute meal deductions, rounding to quarter-hours, work before clocking in/after clocking out, and inclusion of all remuneration in overtime calculations; plaintiffs limited focus to these issues.
- Judge granted partial summary judgment to dismiss eight disputed opt-ins, certified Subclass I (Meal Break Deduction) under Rule 23(b)(3), denied Subclass II (Pre/Postliminary Work) and Subclass IV (ERISA), and denied Subclass III (Regular Rate).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether eight disputed opt-ins should be dismissed from the FLSA action | Disputed plaintiffs may have other viable claims; discovery could reveal material facts. | Interrogatory responses show no unpaid meal break work; responses constitute admissions binding for class eligibility. | Eight disputed opt-ins dismissed from FLSA collective. |
| Whether Subclass I (Meal Break Deduction Class) should be certified | Common policy and common legal questions predominate; damages may be managed collectively. | Issues are not sufficiently cohesive for class treatment given variations in how policy applied. | Subclass I certified under Rule 23(b)(3). |
| Whether Subclass II (Pre and Postliminary Work) should be certified | Policy of working before/after shifts is common and damages manageable. | No uniform policy; individualized inquiries dominate. | Subclass II denied under Rule 23(b)(3); not suitably cohesive. |
| Whether Subclass IV (ERISA Class) can be certified | ERISA claims derive from same policies; class action appropriate for retirement-plan issues. | No evidence about participation or retirement-plan details; fails Rule 23 prerequisites. | Subclass IV denied; ERISA class not certified. |
| Whether the court should exercise supplemental jurisdiction over NYLL claims alongside the FLSA action | Hybrid wage-and-hour action with state-law claims is consistent and efficient. | Hybrid actions are confusing and could overwhelm the FLSA action. | Supplemental jurisdiction over NYLL claims appropriate; hybrid action approved. |
Key Cases Cited
- Gen. Tel. Co. of the Nw., Inc. v. Equal Emp't Opportunity Comm'n, 446 U.S. 318 (U.S. 1980) (numerosity and class treatment framework; foundational standard)
- Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (U.S. 1997) (preemption of class definitions and predominance considerations)
- Robinson v. Metro-North Commuter R.R. Co., 267 F.3d 147 (2d Cir. 2001) (class certification and manageability considerations in § 216(b) actions)
- Gen. Tel. Co. of the Nw., Inc. v. Equal Emp't Opportunity Comm'n, 446 U.S. 318 (U.S. 1980) (numerosity standard and general class-action principles)
- Lindsay v. Gov’t Emps. Ins. Co., 448 F.3d 416 (D.C. Cir. 2006) (supplemental jurisdiction considerations in hybrid actions)
- De Asencio v. Tyson Foods., Inc., 342 F.3d 301 (3d Cir. 2003) (interplay of wage claims and class certification and related issues)
- Damassia v. Duane Reade, Inc., 250 F.R.D. 152 (S.D.N.Y. 2008) (hybrid wage-hour actions and Rule 23 certification considerations)
- Consol. Rail Corp. v. Town of Hyde Park, 47 F.3d 473 (2d Cir. 1995) (numerosity presumptions and collective action context)