Fuchs v. SpecialtyCare, Inc.

District Court, M.D. Tennessee·Decided September 26, 2025·No. 3:23-cv-00892·Unknown

Opinion

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

NATHAN FUCHS et al., ) ) ) Plaintiffs, ) ) v. ) Case No. 3:23-cv-00892 ) CHIEF JUDGE CAMPBELL SPECIALTYCARE, INC., ) MAGISTRATE JUDGE HOLMES )

) Defendant. )

MEMORANDUM Pending before the Court is Plaintiffs Nathan Fuchs’ (“Fuchs”) and Caitlin Bailey’s (“Bailey,” collectively “Plaintiffs”) Motion for Rule 23 Class Certification (“Motion”) (Doc. No. 128) to which Defendant SpecialtyCare, Inc. (“SpecialtyCare”) has filed an Opposition (Doc. No. 144), and Plaintiffs have filed a Reply (Doc. No. 147). For the reasons set forth below, the Motion will be GRANTED in part and DENIED in part. I. BACKGROUND The allegations underlying this case are set forth in detail in the Court’s Memorandum on SpecialtyCare’s Partial Motion to Dismiss. (See Doc. No. 189 at 1–3). Through the pending Motion, Plaintiffs seek to certify two classes of surgical neurophysiologists (“SNs”), formerly employed by SpecialtyCare, in connection with claims arising from an agreement (“Repayment Agreement”), which provides that SNs must pay SpecialtyCare $15,000 to $30,000 if they resign from their jobs within three years. (See Doc. No. 129 at 1).1 Plaintiffs also move the Court to appoint them as class representatives, appoint their attorneys as class counsel, and approve and authorize the distribution of class notice. (See Doc. Nos. 128 at 1, 129 at 17–19). II. STANDARDS GOVERNING CLASS CERTIFICATION

To certify a class, the Court must be satisfied that the requirements of Federal Rule of Civil Procedure 23(a) and at least one of Rule 23(b)’s provisions are met. See Comcast v. Behrend, 569 U.S. 27, 33–34 (2013). Plaintiffs here seek certification under Rules 23(b)(2) and 23(b)(3). The decision whether to certify a class is committed to the sound discretion of the district judge and turns on the particular facts and circumstances of each individual case. See In re Whirlpool Corp. FrontLoading Washer Prod. Liab. Litig., 722 F.3d 838, 850 (6th Cir. 2013). Rule 23(a) establishes four requirements for class certification: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties are typical of those of the class; and (4) the representative parties will fairly and adequately protect the interests of the class. Fed. R.

Civ. P. 23(a). Rule 23(b)(2) allows certification if “the party opposing the class has acted or refused to act on grounds that apply generally to the class, so that final injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole[.]” Fed. R. Civ. P. 23(b)(2). Rule 23(b)(3) allows certification if: the court finds that the questions of law or fact common to class members predominate over any questions affecting only individual members, and that a class action is superior to other available methods for fairly and efficiently adjudicating the controversy. The matters pertinent to these findings include:

1 In light of the Court’s Order (Doc. No. 190) on SpecialtyCare’s Partial Motion to Dismiss, the remaining claims are a violation of the Truth in Lending Act (“TILA”) (Count III), unlawful restraint of trade (Count IV), and unlawful liquidated damages provision (Count V). The Court will not discuss the now-dismissed FLSA claims (Counts I and II). (A) the class members’ interests in individually controlling the prosecution or defense of separate actions; (B) the extent and nature of any litigation concerning the controversy already begun by or against class members; (C) the desirability or undesirability of concentrating the litigation of the claims in the particular forum; and (D) the likely difficulties in managing a class action.

Fed. R. Civ. P. 23(b)(3). Plaintiffs bear the burden of showing that the requirements for class certification are met. Bridging Communities Inc. v. Top Flite Fin. Inc., 843 F.3d 1119, 1124 (6th Cir. 2016). III. ANALYSIS To certify a class, the Court must be satisfied that the requirements of Federal Rule of Civil Procedure 23(a)–numerosity, commonality, typicality, and adequate representation–and at least one of Rule 23(b)’s provisions are met. See Comcast, 569 U.S. at 33–34. In this case, Plaintiffs seek certification of a declaratory relief class under Rule 23(b)(2) and a liability and damages class under Rule 23(b)(3). (See generally Doc. No. 129). The proposed definitions of both classes are identical: “all surgical neurophysiologists employed by SpecialtyCare and subject to its training repayment agreement at any point from August 23, 2017[,] to the present.” (Doc. No. 129 at 2). The Court will analyze the requirements of Rule 23(a) for both proposed classes together and the requirements of Rule 23(b) separately. A. Rule 23(a) 1. Numerosity Rule 23(a)(1) requires that the class be so numerous that joinder of all members is impracticable. “Generally, the number of members of the proposed class, if more than several hundred, easily satisfies the requirements of Rule 23(a)(1).” Hosp. Auth. of Metro. Gov’t of Nashville v. Momenta Pharms., Inc., 333 F.R.D. 390, 403 (M.D. Tenn. 2019) (citing Bacon v. Honda of Am. Mfg., Inc., 370 F.3d 565, 570 (6th Cir. 2004); Bittinger v. Tecumseh Prods. Co., 123 F.3d 877, 884 n.1 (6th Cir. 1997) (joinder of parties impracticable for class with over 1100 members and “[t]o reach this conclusion is to state the obvious”)). However, “as few as forty class members may satisfy the numerosity requirement.” A.M.C. v. Smith, 620 F. Supp. 3d 713, 732

(M.D. Tenn. 2022) (quoting Snead v. CoreCivic of Tenn., LLC, No. 3:17-CV-0949, 2018 WL 3157283, at *11 (M.D. Tenn. June 27, 2018)). Here, “more than 300 SNs have been subject to SpecialtyCare’s [Repayment Agreement] during the [proposed class] period.” (Doc. No. 129 at 1). In addition, SpecialtyCare does not contest numerosity. (See generally Doc. No. 144). Therefore, the Court finds that the proposed classes satisfy this requirement. 2. Commonality Rule 23(a)(2) requires “questions of law or fact common to the class.” Fed. R. Civ. P. 23(a)(2). “The standard is not demanding.” Rockey v. Courtesy Motors, Inc., 199 F.R.D. 578, 583 (W.D. Mich. 2001). “Rule 23(a) simply requires a common question of law or fact.” Bittinger v. Tecumseh Prods. Co., 123 F.3d 877, 884 (6th Cir. 1997). Plaintiffs must show that the class

members’ claims depend upon a common contention of such a nature that it is capable of class- wide resolution. In re Whirlpool Corp., 722 F.3d at 852. “Variation in the ancillary details of the class members’ cases is insufficient to defeat certification, as long as ‘[i]t is unlikely that differences in the factual background of each claim will affect the outcome of the legal issue.’” Grae v. Corr. Corp. of Am., 330 F.R.D. 481, 501 (M.D. Tenn. 2019) (quoting Bacon, 370 F.3d at 570). The proposed classes also pass muster under this factor. Although Plaintiffs raise multiple legal theories, all of their claims revolve around the Repayment Agreement. For instance, whether the Repayment Agreement is unreasonable is a common question for the proposed class. (See Doc. No.

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