443 F.Supp.3d 918
W.D. Tenn.2020Background
- Plaintiff Eugena Stansbury was hired in August 2016 to care for Dr. Lee Faulkner’s ailing mother, working primarily in Faulkner’s home (scheduled 8:00–4:30 M–F; later paid $20/hr). She also briefly worked one day a week in the PoH office early on.
- PoH (Physicians of Hearts, P.L.L.C.) is Faulkner’s cardiology clinic; PoH’s annual gross sales exceeded $500,000 for 2016–2018.
- Stansbury alleges she worked ~55 hours/week from October 2016 to November 2017 and was not paid overtime; terminated May 2018; filed suit under the FLSA for unpaid overtime and liquidated damages.
- Key disputed legal facts: whether PoH was Stansbury’s employer; whether PoH is a covered enterprise; whether the companionship exemption applies or the ‘‘care’’ exception (20% rule) defeats it; adequacy of employer recordkeeping and willfulness for liquidated damages/statute of limitations.
- Cross-motions for summary judgment: Plaintiff sought (1) a ruling that PoH was her employer and (2) enterprise coverage; Defendants sought judgment on companionship exemption, coverage, hours worked, recordkeeping, liquidated damages, and limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Employer-employee relationship (PoH) | PoH employed Stansbury (tax forms, payroll, handbook, included on termination notice). | PoH did not employ her for the relevant period—she worked in Faulkner’s home for the benefit of his household, not the clinic. | Denied for plaintiff: Court found no basis to conclude as a matter of law that PoH "suffered or permitted" the home-care work; factual context showed work primarily for household benefit. |
| Enterprise coverage (29 U.S.C. §203(s)(1)(A)) | PoH is a covered enterprise (employees engaged in commerce; $500k+ sales). | Defendants contested application of handling clause but did not contest gross-volume stipulation. | Granted for plaintiff: PoH is a covered enterprise as a matter of law. |
| Companionship exemption vs. care exception | Stansbury contends much of her work was care/household tasks >20% so exemption fails. | Defendants assert duties were companionship (fellowship/protection) and seek exemption. | Denied for defendants: factual dispute exists whether Stansbury spent >20% time on care tasks; summary judgment inappropriate. |
| Hours worked & recordkeeping | Plaintiff testifies to overtime and produced time records; employer failed to keep accurate records. | Defendants rely on fixed-schedule recordkeeping and paystubs. | Denied for defendants: Stansbury’s testimony and timesheets suffice to create a triable issue; employer’s pay practices may violate recordkeeping rules. |
| Liquidated damages & willfulness/statute of limitations | Stansbury seeks three-year period (willful violation) and full liquidated damages. | Defendants argue good-faith mistake, seek to avoid liquidated damages and limit recovery to two-year period. | Denied for defendants: no affirmative evidence of employer good faith; willfulness and relation-back/statute-of-limitations issues are fact questions for trial. |
Key Cases Cited
- Elwell v. Univ. Hosps. Home Care Servs., 276 F.3d 832 (6th Cir. 2002) (FLSA coverage and overtime principles).
- Brock v. City of Cincinnati, 236 F.3d 793 (6th Cir. 2001) (definition of ‘‘work’’ and ‘‘suffer or permit to work’’).
- Keller v. Miri Microsystems LLC, 781 F.3d 799 (6th Cir. 2015) (economic-reality test context).
- Salyer v. Ohio Bureau of Workers' Comp., 83 F.3d 784 (6th Cir. 1996) (application of companionship exemption).
- O'Brien v. Ed Donnelly Enters., Inc., 575 F.3d 567 (6th Cir. 2009) (employee burden to prove unpaid work).
- Mt. Clemens Pottery Co. v. Anderson, 328 U.S. 680 (1946) (burden-shifting when employer records are inadequate).
- McLaughlin v. Richland Shoe Co., 486 U.S. 128 (1988) (standard for willful violation).
- Sec'y of Labor v. Timberline South, LLC, 925 F.3d 838 (6th Cir. 2019) (employer must show affirmative steps to ascertain FLSA compliance to avoid liquidated damages).
- Ind. Mich. Power Co. v. Martin, 381 F.3d 574 (6th Cir. 2004) (liquidated damages are compensatory; standard for limiting them).