Moffit v. ValueHealth, LLC

CourtDistrict Court, D. Kansas
DecidedMarch 4, 2025
Docket2:23-cv-02408
StatusUnknown

This text of Moffit v. ValueHealth, LLC (Moffit v. ValueHealth, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moffit v. ValueHealth, LLC, (D. Kan. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

JOHN MOFFIT, ) ) Plaintiff, ) CIVIL ACTION ) v. ) No. 23-2408-KHV ) VALUEHEALTH, LLC and DON BISBEE, ) ) Defendants. ) ____________________________________________)

MEMORANDUM AND ORDER This matter is before the Court on plaintiff’s Combined Memorandum Regarding Statutory Penalty And Judgment Amount And Request For Pre-Judgment Interest (Doc. #153) filed January 17, 2025, Defendant ValueHealth, LLC’s Suggestions In Opposition To Plaintiff’s Memorandum Regarding Statutory Penalty And Judgment [Doc. 153] (Doc. #154) and Defendant Don Bisbee’s Response To Plaintiff’s Memorandum Regarding Statutory Penalty And Judgment Amount [Doc. 153] (Doc. #155) both filed January 24, 2025 and Plaintiff’s Reply Memorandum In Support Of Memorandum Regarding Statutory Penalty And Judgment (Doc. #156) filed January 31, 2025. For reasons stated below, the Court awards plaintiff severance pay of $250,000 plus prejudgment interest and a statutory penalty of $250,000 and finds that each defendant is jointly and severally liable for all amounts due under the judgment. Analysis The Court previously determined on summary judgment that under the Kansas Wage Payment Act, K.S.A. § 44-312 et seq. (“KWPA”), plaintiff is entitled to $250,000 in severance pay from ValueHealth, LLC. Memorandum And Order (Doc. #132) filed December 30, 2024 at 13. At trial of the remaining issues, the jury found that in failing to pay that severance pay, ValueHealth willfully violated the KWPA and Don Bisbee knowingly allowed it to do so. Plaintiff

is th erefore entitled to a statutory penalty against ValueHealth, and Mr. Bisbee is jointly liable with ValueHealth. See K.S.A. § 44-315(b); K.S.A. § 44-323(b). The only remaining issues are (1) the amount of statutory penalty and (2) whether plaintiff is entitled to prejudgment interest. I. Amount Of Statutory Penalty As noted, the jury found that ValueHealth willfully violated the KWPA and Mr. Bisbee knowingly allowed it to do so. In such circumstances, the KWPA requires that in addition to requiring payments of unpaid wages, the Court impose a statutory penalty as follows: If an employer willfully fails to pay an employee wages as required by K.S.A. 44- 314, . . . such employer shall be liable to the employee for the wages due and also shall be liable to the employee for a penalty in the fixed amount of 1% of the unpaid wages for each day, except Sunday and legal holidays, upon which such failure continues after the eighth day after the day upon which payment is required or in an amount equal to 100% of the unpaid wages, whichever is less. K.S.A. § 44-315(b). The KWPA also states that “[a]ny officer, manager, major shareholder or other person who has charge of the affairs of an employer, and who knowingly permits the employer to engage in violations of K.S.A. 44-314 or 44-315, and amendments thereto, may be deemed the employer for purposes of this act.” K.S.A. § 44-323(b). Under the parties’ employment contract, ValueHealth owed plaintiff 12 months of his annual salary in severance pay, paid according to regular payroll practices, i.e. monthly installments over 12 months. Plaintiff argues that the penalty accrues on the ninth day after each check was due, which was approximately November 28, 2022. According to plaintiff, the total penalty is over one million dollars but by statute, it is capped at 100 per cent of unpaid wages. Plaintiff therefore argues that the Court should award a statutory penalty of $250,000. Defendants argue that the penalty period did not begin until one of the following dates:

-2- (1) January 7, 2025—eight days after the Court found as a matter of law that ValueHealth did not

have cause to terminate plaintiff’s employment and thus owed him severance pay; (2) January 17, 2025—eight days after the jury verdict; or (3) eight days after judgment is entered. Defendants argue that prior to January of 2025, their liability for severance pay had not been established and they owed no payments to plaintiff. Defendants’ argument has superficial appeal, because it seeks to protect employers who act in good faith or based on mistaken information. Such sympathies would be misplaced in this case, however, because by its terms, the KWPA only assesses penalties for “willful” and “knowing” violations—issues which the jury has resolved against defendants. Defendants do not cite authority for their argument that the statutory penalty does not accrue until liability is determined as a matter of law. Under the employment agreement, the first severance payment was due one month after the termination of plaintiff’s employment, and under the plain language of the KWPA, the penalty accrued nine days later. Beckman v. Kansas Dep’t of Hum. Res., 30 Kan. App. 2d 606, 615, 43 P.3d 891, 898 (2002) (court can assess penalty eight days after wages are due). The penalty period therefore began in December of 2022. Because 100 per cent of the unpaid severance is less than the cumulative daily penalty, the Court awards plaintiff a statutory penalty of $250,000. II. Prejudgment Interest Plaintiff argues that the Court should award him prejudgment interest at the rate of ten per cent on the severance pay and statutory penalty beginning on October 28, 2023, when the last severance check was due, and the statutory penalty had accumulated over the capped amount of $250,000.1

1 This argument is conservative because plaintiff might seek prejudgment interest on (continued. . .)

-3- ValueHealth argues that the Court does not have authority to award prejudgment interest

on t he statutory penalty, so the maximum amount of interest the Court can award is ten per cent interest on unpaid severance pay. Both defendants argue that the Court should not award prejudgment interest on the unpaid severance in addition to the statutory penalty because it would constitute a double penalty and windfall to plaintiff. Under Kansas law, whether to award prejudgment interest is a matter of judicial discretion. Koch v. Koch Indus., Inc., 996 F. Supp. 1273, 1280 (D. Kan. 1998). The KWPA states that “at the discretion of the presiding officer, interest, as provided under K.S.A. 16-201, and amendments thereto, may be assessed on wage claims found to be due and owing from the date the wages were due.” K.S.A. § 44-323. Until 1983, the KWPA did not authorize an award of interest in addition to the statutory penalty. Beckman v. Kansas Dep’t of Hum. Res., 30 Kan. App. 2d 606, 616, 43 P.3d 891, 898 (2002). After the amendment in 1983, however, courts have discretion to award interest on unpaid wages, and the KWPA does not preclude awarding both interest and a penalty. Id. The statutory penalty is punitive in nature. Holder v. Kansas Steel Built, Inc., 224 Kan.

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Related

Holder v. Kansas Steel Built, Inc.
582 P.2d 244 (Supreme Court of Kansas, 1978)
Koch v. Koch Industries, Inc.
996 F. Supp. 1273 (D. Kansas, 1998)
Blair Construction, Inc. v. McBeth
44 P.3d 1244 (Supreme Court of Kansas, 2002)
Beckman v. Kansas Department of Human Resources
43 P.3d 891 (Court of Appeals of Kansas, 2002)
Owen Lumber Co. v. Chartrand
157 P.3d 1109 (Supreme Court of Kansas, 2007)

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Moffit v. ValueHealth, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moffit-v-valuehealth-llc-ksd-2025.