CARTER v. CITY OF PHILADELPHIA

District Court, E.D. Pennsylvania·Decided January 19, 2022·No. 2:18-cv-04404·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LARRY CARTER, et al.,

Case No. 5:18-cv-04404-JDW

v.

CITY OF PHILADELPHIA,

MEMORANDUM Mental Health Emergency Service Coordinators (“MHESC”) filed this civil suit alleging that the City of Philadelphia violated the Fair Labor Standards Act by misclassifying them as exempt and failing to pay overtime wages. The Court granted summary judgment on the misclassification issue. It held a bench trial on damages. After thorough consideration of the evidence presented at trial and relevant law, the Court makes the following findings of fact and conclusions of law pursuant to Fed R. Civ. P. 52(a). I. FINDINGS OF FACT A. Creation Of The MHESC Position 1. At all relevant times, the City of Philadelphia has employed each Plaintiff as a MHESC. 2. The City created the MHESC job classification in 1987 pursuant to the process in its Civil Service Regulations for creating new positions. 3. Under the Civil Service process, the City’s Office of Human Resources and at least one operating department work together to define the job role at issue by describing

and documenting typical examples of work along with any educational or experiential requirements. 4. The Office of Human Resources distributes the resulting document, known

as a job specification, to various stakeholders, including unions if the position is union- represented, before presenting it to the City’s Civil Service Commission at a monthly public meeting for the Commission’s approval. 5. In 1987, following its Civil Service procedures, the City defined the MHESC

responsibilities and experiential requirements at creation as follows: This is a full performance mental health work consulting, advising, and providing a facilitative service to mental health professionals and other city workers on matters pertaining to accessing and managing care for seriously mentally ill persons. Crisis intervention. Referral, and information services are additionally provided for individuals having mental, emotional and social problems. Employees in this class act on behalf of the county administrator, ensuring that actions of the public and professionals in the field are in accordance with established legal mandates, state law and the office’s policies and procedures. Work involves frequent telephone contact with members of the general public, social and mental agency staff, and medical and mental health care professionals, on mental health matters. Significant aspects of the work include reviewing, evaluating, and authorizing psychiatric commitment requests, assessing, prioritizing and diverting psychiatric emergencies, deploying resources, and handling a variety of situations which may be deemed as a threat to life or public safety. Work is performed under the supervision of a technical supervisor. (Ex. 20 at Appx. 185.) 6. The City also defined the MHESC experiential requirements: Completion of a master’s degree program at an accredited college or university with major coursework in psychology, nursing, sociology or social work. One year of counseling or administrative experience handling psychiatric emergencies, which included voluntary or involuntary commitments. Or any equivalent combination of education and experience determined to be acceptable by the Personnel Department which has included the completion of a bachelor’s degree as an educational minimum. ( at Appx. 186.) 7. The Civil Service follows the same procedures when revising existing job descriptions as it does when creating a new one. 8. The City revised the MHESC job class specification in 2003, 2010, and 2017. 9. In 2003, the City revised the experiential requirement from one year to two, and it added language to the general job description stating, “positions in this class are required to work any operational on-site or standby shift as necessary. . .” ( at Appx. 171-176.) 10. In 2010, the City added “mental health counseling” and removed “nursing”

from the job class education requirements, and it increased the amount of general experience required from one year to two. ( at Appx. 178.) 11. In 2017, the City revised language within the job specification to conform with current nomenclature on disabilities. B. FLSA Classifications Of MHESCs 12. Since at least 1987, the Office of Human Resources has reviewed newly

created job positions to determine whether the FLSA covers them. 13. To make FLSA exemption determinations, the Office of Human Resources might have further discussions with a position’s department about the level of

responsibility and scope of functions for the position. 14. The Office of Human Resources may also seek advice from the City Law Department when it has questions about application of the FLSA. 15. There is no record of the City requesting outside counsel or advice from any

state or federal agency with regards to the MHESCs’ FLSA determination. 16. As Deputy Director for Hiring Services for the City of Philadelphia, Janine Labletta is responsible for reviewing FLSA job classifications. Ms. Labletta is familiar with the FLSA via her role within the City of Philadelphia’s Office of Human Resources, but she

does not have any specialized legal expertise or training. 17. The City maintains a process to permit position incumbents or their bargaining representatives to file “FLSA Status Appeals,” which are questionnaires that

document the scope of functions and responsibilities for the position(s) in question. The Office of Human Resources then uses the FLSA Status Appeals to assess whether the City has made the correct FLSA designation for the position. C. MHESC Job Responsibilities 18. At all relevant times, the MHESCs have been part of the City’s Acute Services

Unit. The City employs more than a dozen individuals in this role. 19. MHESCs provide 24 hour-a-day, 7 day-a-week coverage of suicide prevention and mental health crisis intervention phone lines.

20. MHESCs worked forty hours of regularly scheduled time per week. 21. The suicide prevention and mental health crisis intervention lines receive calls from people who are in crisis, their family members, doctors, mental health centers, crisis centers, and members of the general public.

22. The MHESCs’ service responsibilities vary by call type. With suicide prevention line calls, MHESCs are responsible for keeping callers on the line while involving co-workers to get support services to them. 23. When answering crisis intervention line calls, MHESCs may connect with

other behavioral health services, but they may also be asked to dispatch a mobile emergency team or approve a petition for involuntary commitment. 24. If asked to dispatch a mobile emergency team, an MHESC takes the caller’s

information and provides it to a team that makes the ultimate decision on whether to go to the caller. 25. If asked to approve a petition for involuntary commitment, an MHESC may only approve the petition if the behavior described meets four criteria in the Mental

Health Procedures Act. 26. Once an MHESC approves an involuntary commitment petition, the police take the individual in crisis to a crisis response center for a psychiatric evaluation.

27. MHESCs counsel distressed callers in the colloquial sense, but they do not provide clinical counseling. 28. The majority of MHESCs are not licensed to conduct clinical counseling. D. MHESC Compensation Prior To October 2020

29. MHESCs are unionized employees. AFSCME District Council 47, Local 2187, represents them and negotiates the terms and conditions of their employment, including wages. 30. MHESCs worked 8.5 hour shifts that started between 7:30 and 9 a.m. or that

started between 4 and 5:30 p.m. They worked those shifts at a City office in Philadelphia. 31.

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CARTER v. CITY OF PHILADELPHIA, (E.D. Pa. 2022).

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