Burris v. Baxter County Regional Hospital

CourtDistrict Court, W.D. Arkansas
DecidedJanuary 19, 2025
Docket3:23-cv-03008
StatusUnknown

This text of Burris v. Baxter County Regional Hospital (Burris v. Baxter County Regional Hospital) is published on Counsel Stack Legal Research, covering District Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Burris v. Baxter County Regional Hospital, (W.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS HARRISON DIVISION

ANGEL BURRIS, Individually and on Behalf of all Others Similarly Situated PLAINTIFF

V. CASE NO. 3:23-CV-3008

BAXTER COUNTY REGIONAL HOSPITAL, INC. DEFENDANT

MEMORANDUM OPINION AND ORDER TABLE OF CONTENTS

I. BACKGROUND .......................................................................................................... 2 II. COLLECTIVE ACTION DECERTIFICATION ............................................................. 4 A. Factual and Employment Setting ........................................................................ 6 B. Individual Defenses Available to Defendant ...................................................... 8 C. Fairness and Procedural Considerations ........................................................... 9 III. SUMMARY JUDGMENT ......................................................................................... 11 A. Legal Standard ................................................................................................... 11 B. Table A: Time-Barred Plaintiffs ........................................................................... 13 C. Table B: Little or No Overtime ........................................................................... 13 D. Table C: Late-Filed Consents ............................................................................ 14 E. Burris’s Claims ................................................................................................... 16 1. Performance of Uncompensated Work .......................................................... 16 2. Amount and Extent of Work ............................................................................ 17 3. Reasonable Reporting Procedure .................................................................. 18 4. De Minimis Doctrine ......................................................................................... 21 F. Statute of Limitations .......................................................................................... 21 IV. CONCLUSION ......................................................................................................... 23 Now before the Court are Defendant Baxter County Regional Hospital’s Motion to Decertify the Conditional Collective Action (Doc. 75) and Motion for Summary Judgment (Doc. 77). The Court previously conditionally certified a collective action under the FLSA. (Doc. 54). The notice period is now closed, and Baxter County Regional Hospital (“Baxter”) moves to decertify. Baxter also moves for summary judgment against Angel

Burris as class representative, and against particular opt-in plaintiffs who have joined the collective action. Both Motions have been fully briefed by the parties and are ripe for decision. For the reasons below, both motions are DENIED. I. BACKGROUND Plaintiff Angel Burris brought this action on behalf of herself and other hourly, non- exempt, patient care providers employed by Baxter, challenging Baxter’s automatic meal deduction policy, which she claims violates the Fair Labor Standards Act (“FLSA”). The FLSA requires employers to pay overtime to non-exempt employees at a rate not less than one and one-half times an employee's regular rate for all hours worked more than

40 hours in a week. 29 U.S.C. § 207(a)(1). Baxter does not dispute that Plaintiffs are non- exempt. According to Baxter’s company policy, any employee who works at least six and one-half hours is expected to take at least a thirty-minute meal break. (Doc. 47-1, p. 3). And Baxter automatically deducts thirty minutes from employees’ timecards to reflect this break—regardless of whether the employee actually took it. Id. However, Burris and other opt-in Plaintiffs testified in their depositions that their patient-care obligations often prevented them from taking a thirty-minute break. See Doc. 75-2, 33:10–35:8 (Burris Depo.); Doc. 82-2, 29:21–30:11 (Pullen Depo.); Doc. 75-7, 17:1–4 (Helm Depo.). To address this fact, Baxter’s policy “requir[es] those employees to cancel the meal break deduction if their meal breaks were interrupted.” (Doc. 76, p. 19). Baxter provides several methods for their employees to cancel their meal break deduction, and Plaintiffs used those methods to cancel the deduction with varying frequency during their employment. In addition to its routine cancellation methods, Baxter had a system in place to

correct erroneous non-cancellations that came to the Human Resource Department’s attention. Baxter employs approximately 2,000 hourly patient-care providers subject to the lunch deduction. (Doc. 47-1, ¶ 5). Its HR employee, Natalie Amato, says HR corrected erroneous non-cancellations seven times in the five-year period of 2019 through 2023. (Doc. 77-2, ¶ 2). But Baxter admits it violates its own written policy through its cancellation procedure. While its handbook states that “[i]f an employee does not receive a 30-minute uninterrupted meal period, the employee must cancel the [full] meal period,” (Doc. 82-6), when correcting erroneous non-cancellation, Baxter only “ask[s] the employee to determine the amount of time worked that was uncompensated,” and “pay[s] them for that

time.” (Doc. 77-2, ¶ 2). This automatic meal deduction policy is not itself violative of the FLSA, and Burris does not contend as such. See Doc. 54, p. 2. Instead, Burris alleges that Baxter had an unwritten policy of “discouraging its patient care providers from seeking compensation for meal breaks that were interrupted.” (Doc. 82, p. 2). To enforce this policy, Burris alleges Baxter explicitly or implicitly indicated that employees should not cancel the deduction if they got some break1 and chastised employees if deductions were canceled too frequently.2 In July 2024, the Court conditionally certified the following collective action: All hourly, non-exempt, patient care providers (a) who were employed by or on behalf of Baxter County Regional Hospital on or after January 24, 2020, and (b) who received an automatic meal period deduction during the past three (3) years (“Putative Class Members”).

(Doc. 54, p. 10). Over a hundred Baxter employees have opted in to the conditionally certified collective action. At the conditional certification stage, Baxter pressed some of the same arguments as it does now: Burris is not similarly situated to other Plaintiffs because they work in different departments and have different job duties, and she has failed to produce sufficient evidence of an unlawful policy. The Court rejected them then, and Baxter reurges them now, under the heightened evidentiary standards at step two of certification and summary judgment. II. COLLECTIVE ACTION DECERTIFICATION Baxter has moved to decertify, arguing that Burris cannot establish that she and the opt-in Plaintiffs are similarly situated. Burris responds that there is evidence of a

1 Doc. 75-7, 23:25–24:3 (Helm) (“[F]irst I would try to cancel it, because I would be like I didn’t get my full break. But we got to the point that if we got any break, it was considered a break.”); Doc. 75-8, 32:24–25 (Bryant) (“[S]ometimes we were told if it was just a few minutes then it wasn’t a missed meal.”); Doc. 82-3, 45:22–24 (Nash) (“It is the implication that if you were able to eat food, you got a lunch.”).

2 Doc. 82-4, 20:2–7 (Cole Depo.) (“[A] lot of times we would hear it after our manager has gone to a meeting, and then she would come back and say . . . I noticed that y’all have been, you know, saying no lunches a lot. And we need to not be doing that.”); Doc. 75-2, 26:3–6 (Burris) (“[I]f there was kind of an uptick in people hitting the button for a break, seems like we would end up with another staff meeting about it.”); Doc.

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Burris v. Baxter County Regional Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burris-v-baxter-county-regional-hospital-arwd-2025.