Dollery v. Post Acute Medical Specialty Hospital of Corpus Christi, LLC

CourtDistrict Court, S.D. Texas
DecidedFebruary 24, 2023
Docket6:18-cv-00104
StatusUnknown

This text of Dollery v. Post Acute Medical Specialty Hospital of Corpus Christi, LLC (Dollery v. Post Acute Medical Specialty Hospital of Corpus Christi, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dollery v. Post Acute Medical Specialty Hospital of Corpus Christi, LLC, (S.D. Tex. 2023).

Opinion

UNITED STATES DISTRICT COURT February 27, 2023 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk VICTORIA DIVISION DEBRA DOLLERY, on behalf of herself § and all others similarly situated, § § Plaintiffs, § § v. § Civil Case No. 6:18-CV-00104 § POST ACUTE MEDICAL, LLC, POST § ACUTE MEDICAL MANAGEMENT, § LLC, and POST ACUTE MEDICAL § AT VICTORIA, LLC, § § Defendants. § MEMORANDUM OPINION AND ORDER Debra Dollery was employed as a nurse at the Post Acute Specialty Hospital of Victoria from August 2013 to May 2018. She alleges that her employer engaged in certain practices that violated the Fair Labor Standards Act (“FLSA”), and she has filed this Civil Action on behalf of herself and others similarly situated against Defendants Post Acute Medical LLC, Post Acute Medical Management LLC, and Post Acute Medical at Victoria, LLC. Dollery generally alleges that Defendants failed to properly compensate certain non-exempt hourly employees. On July 27, 2020, this Court granted the Parties’ Joint Stipulation for the conditional certification of a collective action. Pending before the Court is Defendants’ Motion to Decertify Plaintiffs’ Conditionally Certified FLSA Collective Action, (Dkt. No. 189). For the following reasons, the Court DENIES the Motion. I. BACKGROUND Defendants own and operate a network of hospitals across the United States that provide long-term acute care and inpatient rehabilitation services. (Dkt. No. 189 at 8).

Dollery was employed as a nurse at the Post Acute Specialty Hospital of Victoria from August 2013 to May 2018. (Dkt. No. 1 at 3). In that position, Dollery’s primary responsibilities included “providing patient care and monitoring, administering medicine to patients, interacting with other hospital employees and visitors, monitoring blood-work and patient test results, and responding to emergency situations.” (Id. at 6).

On December 18, 2018, Dollery filed a collective-action lawsuit on behalf of herself and all other similarly situated individuals who worked for the Defendants as nurses, nurse aides, nurse assistants, and other non-exempt hourly employees (the “nursing staff”). (Id. at 1). Dollery contends that the nursing staff are similarly situated for purposes of this lawsuit because they (1) report to the same hospital or clinical facility that is owned and operated by Defendants, (2) perform similar jobs, (3) are subject to the

same work, time, pay, meal and rest break, and overtime policies, (4) are paid hourly, and (5) work similar hours. (Id. at 7–8). Dollery raises three separate FLSA violations. First, she alleges that Defendants automatically deduct 30 minutes from the nursing staff employees’ hours worked for meal breaks regardless of whether such employees received a full, uninterrupted break. (Id. at 5–6).1 Second, Dollery alleges that Defendants required nursing staff employees to perform off-the-clock work without compensation. (Id. at 6). And third, Dollery alleges

that Defendants failed to pay the nursing staff employees overtime wages when the inclusion of the 30-minute meal break and off-the-clock work would have resulted in more than 40 hours worked in a week. (Id. at 7–8). On July 27, 2020, this Court granted the Parties’ Joint Stipulation for Conditional Certification and Notice. (Dkt. No. 99). This Court noted that the collective members were defined by the Parties as: “All non-exempt registered nurses, licensed practical

nurses, licensed vocational nurses, certified nursing assistants, and nursing aides employed by Defendants and paid on an hourly rate basis at any time from March 16, 2017 to the Present.” (Id. at 1) (emphasis removed). The Parties agreed to complete discovery by June 20, 2022, (Dkt. No. 142 at 1), with any motion for decertification to be filed within 90 days from the close of discovery, (id.). On September 15, 2022, Defendants

filed their Motion to Decertify Plaintiffs’ Conditionally Certified FLSA Collective Action. (Dkt. No. 189). The sole issue before this Court is whether to decertify Plaintiffs’ conditionally certified FLSA collective action. II. APPLICABLE LAW Section 216(b) of the FLSA provides that a plaintiff may maintain an action on “behalf of himself . . . and other employees similarly situated” to recover “unpaid

1 Defendants do not dispute that, prior to October 2019, such a policy existed. (Dkt. No. 189 at 10). However, beginning in October 2019, the hospital policy requires nurses to manually punch in and punch out for their meal breaks. (Id.). minimum wages” or “unpaid overtime compensation[.]” 29 U.S.C. § 216(b). Until recently, the Fifth Circuit had not announced a legal standard for collective-action

certification. Swales v. KLLM Transp. Servs. L.L.C., 985 F.3d 430 (5th Cir. 2021). Prior to this new rule, most district courts in the Fifth Circuit employed a two-step certification process announced in Lusardi v. Xerox Corp.2 Swales, 985 F.3d at 436. Step one, which is referred to as the “conditional certification” of a putative class, involves an initial determination that the proposed members of a collective are similar enough to receive notice of the pending action. Id. The district court considers whether,

based on the pleadings and affidavits of the parties, the putative collective members are similarly situated and may proceed collectively. Id. at 436–37; In re JPMorgan Chase & Co., 916 F.3d 494, 501 (5th Cir. 2019). Step two occurs at the conclusion of discovery, often prompted by a motion to decertify. Swales, 985 F.3d. at 437; Reyna v. Int’l Bank of Com., 839 F.3d 373, 374–75 (5th Cir. 2016). The district court then makes “a final determination

of whether all plaintiffs are sufficiently similarly situated to proceed together in a single action.” Reyna, 839 F.3d at 375 n.2 (internal quotation marks). If the court finds that the opt-ins are not sufficiently similar to the named plaintiffs, it “must dismiss the opt-in employees, leaving only the named plaintiff’s original claims.” Swales, 985 F.3d at 437 (quoting Sandoz v. Cingular Wireless LLC, 553 F.3d 913, 915 n.2 (5th Cir. 2008) (internal

quotation marks omitted)).

2 118 F.R.D. 351 (D.N.J. 1987). In Swales, the Fifth Circuit rejected the Lusardi two-step approach, and instead advised district courts to “identify, at the outset of the case, what facts and legal

considerations will be material to determining whether a group of ‘employees’ is ‘similarly situated.’ And then it should authorize preliminary discovery accordingly.” Swales, 985 F.3d at 440–41. The Fifth Circuit further noted that when deciding if the named plaintiff has met its burden of establishing similarity, a “district court has broad, litigation-management discretion.” Id. at 443. While the Fifth Circuit provided guidance to district courts on how to handle FLSA

cases at the outset (i.e., pre-notice), it was less specific about how to manage cases that were conditionally certified under Lusardi but did not have a decertification motion resolved before Swales. In other words, cases that were through step one of Lusardi, but not step two. Several district courts within the Fifth Circuit have held that “the case essentially remains the same as it would have been pre-Swales” when faced with a

collective-action case between step one and step two. Segovia v. Fuelco Energy LLC, No. 5:17-CV-01246, 2021 WL 2187956, at *6 (W.D. Tex. May 28, 2021); Mondeck v. LineQuest, LLC, No.

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Dollery v. Post Acute Medical Specialty Hospital of Corpus Christi, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dollery-v-post-acute-medical-specialty-hospital-of-corpus-christi-llc-txsd-2023.