Withrow v. Sedgwick Claims Management Service, Inc., 841 F. Supp. 2d 972

Sedgwick Claims Management Services administers 17,000 WV workers’ compensation claims from its Charleston office; claims arose before July 1, 2005 (“old-fund”).
Plaintiffs Were Claims Examiners II/III and Paula Ball (utilization review nurse turned telephonic case manager) with non-manual, claim-management duties.
Dispute centers on FLSA overtime exemptions: administrative exemption for most Examiners and professional exemption for Ball; WVWPCA claim also alleged.
Plaintiffs alleged duties included claim maintenance, treatment authorization, reserves, settlements, litigation handling, fraud/subrogation reviews, and action plans.
Court granted Sedgwick’s Summary Judgment on FLSA claims for all plaintiffs and Ball; denied plaintiffs’ MSJ and conditional certification; WVWPCA claim dismissed as moot.
Procedural posture: case removed from WV state court; Second Amended Complaint pleaded three counts (FLSA overtime, collective action under §216(b), WVWPCA).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Examiners’ duties satisfy the administrative exemption	Withrow et al. argue duties are production-like, not management-related.	Examiners’ primary duties directly relate to management/business operations and require discretionary judgments.	No genuine issue; Examiners meet administrative exemption.
Whether Ball’s duties meet the professional exemption	Ball argues not necessary to dissect; Ball’s nursing duties are professional.	Ball’s duties involve advanced medical knowledge and judgment; qualifies as learned professional.	Ball’s duties fall under learned professional exemption.
Whether WVWPCA claim survives after FLSA ruling	WVWPCA claim independently viable for overtime-related payments.	WVWPCA claim fails as FLSA claim is resolved in Sedgwick’s favor.	WVWPCA claim dismissed as moot.
Whether FLSA collective action certification remains viable	Plaintiffs seek conditional certification under §216(b).	Complete dismissal of FLSA claims warrants denial of certification.	Denied as moot because FLSA claims against all plaintiffs were granted to Sedgwick.
Court’s treatment of post-2010 duties for Webb	Webb’s duties after 2010 still included settlements and reserves.	Settlements moved to a dedicated team; third prong still satisfied for Webb.	Third prong satisfied for Webb; exemption remains proper.

Robinson-Smith v. Gov't Emps. Ins. Co., 590 F.3d 886 (D.C. Cir. 2010) (administrative exemption and discretion analysis in adjusters)
In re Farmers Ins. Exch., 466 F.3d 853 (9th Cir. 2006) (exemption for claims adjusters; not all activities listed must be performed)
Cheatham v. Allstate Ins. Co., 465 F.3d 578 (5th Cir. 2006) (administrative exemption for adjusters; the presence of supervision not required)
McAllister v. Transamerica Occidental Life Ins. Co., 325 F.3d 997 (8th Cir. 2003) (discretionary duties can accompany manuals or guidelines)
Roe-Midgett v. CC Servs., Inc., 512 F.3d 865 (7th Cir. 2008) (claims adjusters’ discretion and settlement authority; related to admin exemption)
Desmond v. PNGI Charles Town Gaming, L.L.C., 564 F.3d 688 (4th Cir. 2009) (racing officials not exempt; focus on duties, not indispensability)
In re Farmers Ins. Exch., and related Second Circuit cited Reich v. John Alden Life Ins. Co., 126 F.3d 1 (1st Cir. 1997) (production vs. administrative exemption framing)