Barta v. SpecialtyCare, Inc.

CourtDistrict Court, M.D. Tennessee
DecidedSeptember 23, 2025
Docket3:24-cv-01335
StatusUnknown

This text of Barta v. SpecialtyCare, Inc. (Barta v. SpecialtyCare, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barta v. SpecialtyCare, Inc., (M.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

HAYLEY BARTA, ET AL., ) ) Plaintiffs, ) ) NO. 3:24-cv-01335 v. ) ) JUDGE CAMPBELL SPECIALTYCARE, INC., ) MAGISTRATE JUDGE NEWBERN ) Defendant. )

MEMORANDUM Pending before the Court is Plaintiffs’ Motion for Issuance of Court-Authorized Notice. (Doc. No. 36). Defendant filed a response in opposition (Doc. No. 47), and Plaintiffs filed a reply (Doc. No. 66). For the reasons discussed below, the motion will be GRANTED in part and DENIED in part. I. FACTUAL BACKGROUND Defendant provides intraoperative neurophysiological monitoring (“IONM”) services to hospitals across the county, which involves monitoring and observing patients in operating rooms and communicating with doctors regarding changes in the nerve system function. (Doc. No. 37 at 3). Plaintiffs seek to represent a collective consisting of “[a]ll persons who worked for Defendant as salaried Surgical Neurophysiologists (“SNs”) and were treated by Defendants as exempt within the United States at any time during the last three (3) years prior to the filing of this Complaint.” (Doc. No. 33 ¶ 49). Plaintiffs contend that Defendant classifies its salaried SNs by various job titles, including SN II, SN III, Senior SN I, Senior SN II, and Senior SN III, but that each SN performed the same primary job duty of providing IONM services in operating rooms. (Doc. No. 37 at 1). Plaintiffs contend that all putative collective members are not paid for hours worked in excess of 40 in a work week because Defendant uniformly classifies its salaried SNs as exempt from overtime under the FLSA. Plaintiff Hayley Barta worked as an SN for Defendant from February or March 2017 to April 2024 in Tennessee and Kansas. During her employment with Defendant, Barta worked as an

SN I, SN II, and SN III. (Id. at 4). Plaintiff Lindsay Lojewski worked as an SN III for Defendant in Maryland from August 2017 to October 2019. (Id. at 4). In July 2021, Lojewski worked as a SN III for Defendant in California. Plaintiff Lucas Barradas has worked for Defendant as an SN II and SN III in Pennsylvania since October 2016. (Doc. No. 38-5 ¶¶ 2-3, 6). Plaintiffs bring claims against Defendant for failure to pay overtime in violation of the FLSA. Plaintiff Lojewski also brings claims for violation of California’s wage and hour laws and requests that the Court certify a class of “[a]ll persons who worked for Defendant as salaried Surgical Neurophysiologists (“SNs”) and were treated as exempt within the State of California at any time during the last four (4) years prior to the filing of this Complaint.” (Doc. No. 33 ¶ 57). Plaintiff Barradas brings claims for violation of the Pennsylvania Minimum Wage Act and requests

that the Court certify a class of “[a]ll persons who worked for Defendant as salaried Surgical Neurophysiologists (“SNs”) and were treated as exempt within the State of Pennsylvania at any time during the last three years prior to the filing of this Complaint.” (Doc. No. 33 ¶ 66). In support of their motion, Plaintiffs submitted the declarations of the named Plaintiffs and 7 other salaried SNs assigned to various geographical markets and SN job positions. (Doc. No. 38- 5). Plaintiffs also submitted Defendant’s job postings for open SN positions, incentive pay program for exempt associates, including SNs II-IV, Senior SNs 1-III, SN Clinical Travelers, and IONM Clinical Managers, Defendant’s IONM training program, and Defendant’s IONM Career Ladder Guideline.1 (See Doc. Nos. 38-1, 38-2, 38-3, 38-4, 38-6). Plaintiffs contend that they and the putative collective members are similarly situated because they share the same primary job duty of providing IONM services, are similarly paid by salary, work overtime hours, and are subject to Defendant’s uniform policy of being classified as exempt from overtime pay. (Doc. No. 37 at 10).

Plaintiffs also request that the Court authorize their proposed notice consisting of a 60-day notice period and approve notice via U.S. mail, email, and text message, along with a reminder notice via U.S. mail and email 21 days before the end of the notice period. Plaintiffs request that Defendant be required to disclose names and contact information for all putative collective members within 7 days of the Court’s Order to effectuate notice. Defendant opposes Plaintiffs’ motion. (Doc. No. 47). II. STANDARD OF REVIEW A collective action hinges on “employees receiving accurate and timely notice concerning [its] pendency ... so that they can make informed decisions about whether to participate.” Hoffmann–La Roche Inc. v. Sperling, 493 U.S. 165, 170 (1989). “[F]or a district court to facilitate

notice of an FLSA suit to other employees, the plaintiffs must show a ‘strong likelihood’ that those employees are similarly situated to the plaintiffs themselves.” Clark v. A&L Homecare and Training Ctr., LLC, 68 F.4th 1003, 1011 (6th Cir. 2023). “That standard requires a showing greater than the one necessary to create a genuine issue of fact, but less than the one necessary to show a preponderance.” Id. After notice has issued, employees have opted into the collective action, and discovery has continued, the district court determines—not conditionally, but conclusively—

1 Plaintiffs also submitted evidence of job descriptions for SN II, SN III, and SN IV positions, which represent that these positions are classified as exempt and share the same essential duties and responsibilities.1 (Doc. No. 38-4). However, Defendant contends that these job descriptions were discontinued in 2015 and are irrelevant to Plaintiffs’ motion. The Court did not rely on this exhibit in its analysis and thus, need not address Defendant’s argument. whether the collective members are in fact “similarly situated” to the original plaintiffs. Id. at 1010-11. III. ANALYSIS A. Putative Collective Members

Plaintiffs contend that they are similarly situated to putative collective members because they are all salaried employees classified as exempt from overtime pay and share the same primary job duties and responsibilities of providing IONM services. “Whether other employees are similarly situated for the purpose of joining an FLSA suit typically depends on whether they performed the same tasks and were subject to the same policies—as to both timekeeping and compensation—as the original plaintiffs were.” Clark, 68 F.4th at 1010. The Sixth Circuit considers the following factors to determine whether collection action members are similarly situated: “(1) the ‘factual and employment settings of the individual[] plaintiffs’; (2) ‘the different defenses to which the plaintiffs may be subject on an individual basis’; and (3) ‘the degree of fairness and procedural impact of certifying the action as a collective

action.’” Isaacs v. Landmark Recovery of Louisville, LLC, No. 3:23-CV-00210, 2023 WL 6096730, at *10 (M.D. Tenn. Sept. 18, 2023) (citing Monroe v. FTS USA, LLC, 860 F.3d 389, 397 (6th Cir. 2017)). Further, “Plaintiffs are similarly situated if they can demonstrate that they suffered from ‘a single, FLSA-violating policy’ instituted by the employer defendant, or if their ‘claims [are] unified by common theories of defendants' statutory violations, even if the proofs of these theories are inevitably individualized and distinct.’” Clark, 68 F.4th at 1010 (internal citations omitted).

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Hoffmann-La Roche Inc. v. Sperling
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Gina Glazer v. Whirlpool Corporation
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Edward Monroe v. FTS USA, LLC
860 F.3d 389 (Sixth Circuit, 2017)
Colley v. Scherzinger Corp.
176 F. Supp. 3d 730 (S.D. Ohio, 2016)
Crosby v. Stage Stores, Inc.
348 F. Supp. 3d 742 (M.D. Tennessee, 2018)
Brooke Clark v. A&L Homecare &Training Ctr.
68 F.4th 1003 (Sixth Circuit, 2023)

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Barta v. SpecialtyCare, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/barta-v-specialtycare-inc-tnmd-2025.