Rieve v. Coventry Health Care, Inc.
870 F. Supp. 2d 856
C.D. Cal.2012Background
- Plaintiff Julia Rieve sued Coventry Health Care, CHC-WC, alleging improper exempt classification and related wage, PAGA, UCL, and wage-statement claims.
- Rieve, an RN, held Field Case Manager–Med (FCM-Med) duties, with no direct patient care and fixed weekly salary.
- FCMs documented costs, prepared care plans, and advised on medical services but did not order or modify physician treatment.
- Physicians ordered treatment; claims adjusters could approve/deny care; FCMs acted as information conduits and cost-identifiers.
- Court granted partial summary judgment for Plaintiff sua sponte on California overtime exemptions, and denied others; trial on remaining issues remains.
- Questions include whether FLSA professional exemption applies and whether California exemptions and related claims survive, with CHC liability contested.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does FLSA professional exemption apply to Rieve | Rieve argues duties involve advanced knowledge. | CHC argues FLSA exemption applies. | Court finds FLSA professional exemption applies. |
| Are California overtime exemptions (professional/administrative) applicable | California exemptions should apply; substantially similar duties. | Exemptions may apply under California Wage Order 4-2001. | Court sua sponte grants Plaintiff summary judgment on California exemptions (not exempt). |
| Is Plaintiff exempt under California administrative exemption | Administrative exemption should cover duties. | Administrative exemption applies; evidence disputed. | Court determines Plaintiff not administratively exempt. |
| Section 226 wage-statement claim viability | Failure to provide wage statements constitutes injury. | Status of exemption bears on liability; disputed. | Not dispositive; jury to resolve knowing violations. |
| UCL and PAGA claims viability given overtime findings | Overtime/supply violations support UCL and PAGA. | Prevailing on overtime negates related claims. | UCL and PAGA claims survive given overtime findings. |
Key Cases Cited
- Withrow v. Sedgwick Claims Mgmt., 841 F.Supp.2d 972 (S.D.W.Va.2012) (exemption for nurse case managers under FLSA)
- Powell v. American Red Cross, 518 F.Supp.2d 24 (D.D.C.2007) (advanced knowledge showed non-routine, individualized care decisions)
- Chatfield v. Children’s Services, Inc., 555 F.Supp.2d 532 (E.D.Pa.2008) (case managers exercised independent discretion)
- Harris v. Superior Court, 53 Cal.4th 170 (Cal. 2011) (limits of administrative exemption under Harris framework)
- Ramirez v. Yosemite Water Co., 20 Cal.4th 785 (Cal.1999) (narrow construction of exemptions; state vs federal scope)