MATTHEWS v. PHILADELPHIA CORPORATION FOR AGING

CourtDistrict Court, E.D. Pennsylvania
DecidedApril 1, 2025
Docket2:22-cv-04632
StatusUnknown

This text of MATTHEWS v. PHILADELPHIA CORPORATION FOR AGING (MATTHEWS v. PHILADELPHIA CORPORATION FOR AGING) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MATTHEWS v. PHILADELPHIA CORPORATION FOR AGING, (E.D. Pa. 2025).

Opinion

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

NEQUAVA MATTHEWS : CIVIL ACTION : v. : NO. 22-4632 : PHILADELPHIA CORPORATION : FOR AGING :

MEMORANDUM

MURPHY, J. April 1, 2025

Nequava Matthews, on behalf of herself and others similarly situated, brought this hybrid class and collective action against her former employer, Philadelphia Corporation for Aging (“PCA”), alleging misclassification of certain employees as exempt from overtime pay in violation of the Fair Labor Standards Act (“FLSA”) and the Pennsylvania Minimum Wage Act (“PMWA”). See DI 1 at 1. Following discovery and two lengthy mediation sessions, the parties reached a proposed settlement. See DI 70-3 at 11. We preliminarily approved the settlement and notice process and held a hearing to resolve any objections and to hear argument from counsel. See DI 71; DI 77. Ms. Matthews now moves unopposed for final approval of the settlement, including certification of the class under Rule 23 and collective under FLSA § 16(b), approval of the service and attorneys’ fee awards, and dismissal of the case with prejudice. DI 75 at 1-2. Having reviewed the motion and supporting materials, including the final proposed settlement agreement, DI 75-1, the declarations submitted by counsel and the settlement administrator, DI 75-2; DI 76-1, and the parties’ presentations at the March 6 fairness hearing, we grant the requested relief. I. Background PCA employed older adult protective services (“OAPS”) investigators to investigate allegations of elder abuse and similar matters. DI 75-3 at 1. Plaintiff alleges that, between November 2019 and August 2024, PCA classified these investigators as salaried employees

exempt from overtime pay. Id. at 2-5, 8-9. She contends that this classification violated both the FLSA and PMWA because OAPS Investigators primarily performed non-exempt work and regularly worked more than 40 hours per week without overtime compensation. Id. at 2 Plaintiff filed this lawsuit in November 2022, and in front of us now is a proposed settlement to that lawsuit. See DI 1; DI 75; DI 76; DI 79; DI 80. The settlement provides for a maximum of $975,000 to resolve all claims, including those of both Rule 23 class members and FLSA opt-ins. See DI 75-1 at 10-13. In exchange, class members release wage-and-hour claims arising during the covered period. Id. at 8-9. On January 11, 2025, we granted preliminary approval of the settlement and authorized notice to the class. See DI 71. The notice period closed on March 3, 2025. See DI 79. No

objections were submitted. See DI 76-1 ¶ 15; DI 79; DI 80. Plaintiff, unopposed, now seeks final approval for her hybrid class and FLSA collective action.1 See DI 75; DI 76; DI 79; DI 80.

1 We note the inherent uncertainty in the law regarding whether Rule 23 certification is required in hybrid FLSA and state-law wage actions where there is no opt-out requirement. While FLSA collective actions require potential plaintiffs to affirmatively opt-in, see 29 U.S.C. § 216(b), Rule 23 class actions typically bind all class members who do not opt out. Here, however, the settlement class effectively operates as an opt-in collective, because it affects only those who affirmatively return consent forms. See, e.g., Knepper v. Rite Aid Corp., 675 F.3d 249, 258-59 (3d Cir. 2012) (recognizing potential tension between opt-in FLSA collective actions and opt-out Rule 23 state-law class actions); Reinig v. RBS Citizens, N.A., 912 F.3d 115, 131-33 (3d Cir. 2018) (same).

2 II. Certification A. The proposed class is certified under Rule 23 A class may be certified for settlement purposes if it meets the requirements of Rule 23(a) and at least one provision of Rule 23(b). See Fed. R. Civ. P. 23(a)-(b); Amchem Prods.,

Inc. v. Windsor, 521 U.S. 591, 613, 619-22 (1997). The proposed settlement class includes individuals employed by PCA as OAPS Investigators between November 18, 2019 and August 20, 2024 who returned timely consent forms. DI 75-1 at 4; DI 75-3 at 17. Noting again that no objections have been made, we find that that Rule 23(a)’s requirements are satisfied. 1. Rule 23(a) Under Rule 23(a), we consider: “(1) numerosity (a class so large that joinder of all members is impracticable); (2) commonality (questions of law or fact common to the class); (3) typicality (named parties' claims or defenses are typical of the class); and (4) adequacy of representation (representatives will fairly and adequately protect the interests of the class).” Amchem, 521 U.S. at 613 (quotations omitted and cleaned up).

Numerosity is satisfied when the class is large enough that joinder would be impracticable. See In re Nat’l Football League Players Concussion Inj. Litig., 821 F.3d 410,

At the fairness hearing, counsel for both parties indicated that they pursued dual certification under Rule 23 and the FLSA out of an abundance of caution. We accordingly proceed under the hybrid framework chosen by the parties. Cf. In re Baby Prods. Antitrust Litig., 708 F.3d 163, 175 (3d Cir. 2013) (“Mindful that we are dealing with a settlement, we remain hesitant to undo an agreement that has resolved a hard-fought, multi-year litigation.”). However, we would advise future litigants seeking approval of similar hybrid settlements in this court to highlight this issue clearly and early in the litigation and to brief specifically whether Rule 23 certification is necessary or appropriate under the circumstances. Cf. Alcantara v. Duran Landscaping, Inc., No. 21-3947, 2022 WL 2703610, at *3-5 (E.D. Pa. July 12, 2022) (arguing persuasively that settlement approval is not required in an FLSA collective action). Often it may not be. 3 426 (3d Cir. 2016), as amended (May 2, 2016) (noting that classes of 40 or more are generally sufficient). The class is sufficiently numerous, with 53 members identified by name. See DI 76; DI 79; DI 80. Commonality requires that class members share at least one common issue of law or fact.

See Baby Neal v. Casey, 43 F.3d 48, 56 (3d Cir. 1994). This requirement “is easily met” where the claims stem from a common policy or practice. Id. The class members here were all subject to the same alleged misclassification as exempt employees under PCA’s pay practices, raising shared factual and legal questions about the applicability of federal and state wage laws. See DI 10 ¶ 13. Typicality assesses whether the named plaintiff’s claims arise from the same course of conduct and are based on the same legal theories as the claims of the class. See Baby Neal, 43 F.3d at 57-58 (“Where an action challenges a policy or practice, the named plaintiffs suffering one specific injury from the practice can represent a class suffering other injuries, so long as all the injuries are shown to result from the practice.”). Ms. Matthews alleges that she, like the

other class members, was a PCA OAPS investigator classified as exempt and denied overtime pay, rendering her claims typical of the class. See DI 1 ¶¶ 11-12. Adequacy requires that the named plaintiff and class counsel fairly and competently represent the interests of absent class members. See In re Prudential Ins. Co. Am.

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MATTHEWS v. PHILADELPHIA CORPORATION FOR AGING, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matthews-v-philadelphia-corporation-for-aging-paed-2025.