O'Dell v. Aya Healthcare, Inc.

CourtDistrict Court, S.D. California
DecidedApril 27, 2023
Docket3:22-cv-01151
StatusUnknown

This text of O'Dell v. Aya Healthcare, Inc. (O'Dell v. Aya Healthcare, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Dell v. Aya Healthcare, Inc., (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 LAURA O’DELL, HANNAH ) Case No.: 3:22-cv-01151-BEN-BLM BAILEY, HOLLY ZIMMERMAN, ) 12 and LAUREN MILLER, individually ) ORDER: 13 and on behalf of all others similarly ) situated, ) (1) GRANTING-IN-PART MOTION 14 ) TO COMPEL ARBITRATION; AND Plaintiffs, 15 ) v. ) (2) DENYING EX PARTE 16 ) APPLICATION WITHOUT AYA HEALTHCARE, INC., 17 ) PREJUDICE Defendant. ) 18 ) [ECF Nos. 21, 29] 19 20 21 I. INTRODUCTION 22 Plaintiffs Laura O’Dell, Hannah Baily, Holly Zimmerman, and Lauren Miller, 23 individually and on behalf of all others similarly situated, (collectively, “Plaintiffs”) bring 24 this action against Defendant Aya Healthcare, Inc. (“Aya”) alleging breach of contract and 25 various related claims. Before the Court is: (1) Aya’s Motion to Compel Arbitration; (2) 26 Plaintiffs’ request for a jury trial on the issue of arbitration; and (3) Aya’s Ex Parte 27 Application for a Temporary Restraining Order and Request for Preliminary Injunction. 28 The Motion to Compel Arbitration was submitted on the papers without oral argument 1 pursuant to Civil Local Rule 7.1(d)(1) and Rule 78(b) of the Federal Rules of Civil 2 Procedure. See ECF No. 32. After considering the papers submitted, supporting 3 documentation, and applicable law, the Court: (1) GRANTS-IN-PART Aya’s Motion to 4 Compel Arbitration; (2) DENIES Plaintiffs’ request for a jury trial on the issue of 5 arbitration; and (3) DENIES without prejudice Aya’s Ex Parte Application for a 6 Temporary Restraining Order and Request for Preliminary Injunction. 7 II. BACKGROUND 8 Plaintiffs’ claims against Aya arise from the alleged breach of an employment 9 contract between the parties. 10 A. Statement of Facts1 11 To fill travel nursing roles, “healthcare facilities utilize intermediary staffing 12 agencies to employ the travelers, negotiate pay rates, and schedule assignments.” ECF No. 13 15 (“FAC”) at 2, ¶ 1. Aya is a Delaware corporation with its principal place of business in 14 San Diego, California and “contracts with healthcare facilities to staff open positions.” Id. 15 at 4, ¶ 10; 5, ¶ 17. “Aya is offering contracts to travel nurses with a fixed-term assignment 16 at an agreed-upon pay rate.” Id. at 2, ¶ 2. “Aya knows that in order to accept these 17 assignments, many nurses must give up their current employment, move to the location of 18 the facility (oftentimes out-of-state), secure short-term housing, and incur other travel and 19 housing related costs at their own expense.” Id. at 6, ¶ 18. 20 “Aya utilizes form employment agreements for its traveling employees,” but “knows 21 that its agreements are premised on false promises and that it does not intend to pay its 22 travel employees the” promised hourly rate. Id. at 6, ¶ 20. “After the nurse accepts the 23 position and starts the assignment, Aya makes a ‘take-it-or-leave-it’ demand to accept less 24 pay or to be terminated.” Id. “[M]ost nurses have no choice but to continue working the 25 assignment at the lower rate because they have no reasonable alternatives for comparable 26 27 1 The majority of the facts set forth herein are taken from Plaintiffs’ Complaint. However, the text of the arbitration agreements at issue is taken directly from those 28 1 employment: they have already incurred travel expenses, secured short-term housing, and 2 uprooted their lives to accept the assignment.” Id. “Hundreds if not thousands of nurses 3 employed by Aya across the country have reported experiencing mid-contract pay 4 reductions after starting an assignment with Aya, with many reporting that Aya reduced 5 their pay multiple times within the same assignment or slashed their pay by more than 50% 6 or more than originally promised.” Id. at 2, ¶ 3. In addition to this “bait-and-switch” 7 practice, “Aya is underpaying its travel employees for overtime hours worked” in violation 8 of the law. Id. at 3, ¶¶ 4–5. 9 Employees would receive an email (which is copy and pasted into the FAC) that 10 notifies the employee of pay rate changing mid-contract, and attributing the cause to 11 “hospitalizations leveling out and COVID cases decreasing . . . .” Id. at 7, ¶ 22. “[M]any 12 employees whose pay was cut questioned this explanation as they did not work in a COVID 13 unit and the number of COVID cases had no impact on their job responsibilities.” Id. at 7, 14 ¶ 23. The FAC alleges “there is evidence that hospitals did not actually decrease their bill 15 rates, and Aya simply made this up to justify decreasing the hourly pay rates of its 16 employees, thus increasing its own margins.” Id. at 7, ¶ 24. “For example, after receiving 17 a pay reduction, multiple Aya employees reported speaking directly with hospital 18 representatives who confirmed that the hospital never decreased the bill rate for the 19 employee’s assignment.” Id. at 7–8, ¶ 24. However, the FAC further alleges that “[e]ven 20 if a hospital did change the bill rate . . . , nothing in Aya’s contract permits it to pass along 21 those decreases onto their unsuspecting employees.” Id. at 8, ¶ 25. The contractually 22 agreed upon pay rate “was not in any way dependent on the actions of a third party or Aya 23 making a pre-determined margin.” Id. 24 In certain, limited circumstances, “Aya employees have even been able to confirm 25 their bill rate directly with the hospital and were shocked to learn that Aya’s margins were 26 in some instances 65% or higher than what Aya was paying the employee.” Id. at 8, ¶ 26. 27 When employees have learned of said bill rates, “Aya has threatened staff members at 28 hospitals for disclosing it or taken retaliatory actions against the employees for purportedly 1 ‘discussing their pay’ in violation of Aya’s policies.” Id. at 8, ¶ 27. The FAC cites an 2 example where a nurse learned about the rates, convinced Aya to agree to pay her more out 3 of Aya’s margin, and subsequently received a voicemail from an Aya recruiter stating that 4 they could no longer approve that payout because the nurse had shared her pay with other 5 nurses. Id. at 9–10, ¶ 27. The FAC alleges that this conduct of “prohibiting employees 6 from discussing their pay is expressly prohibited by the National Labor Relations Act.” Id. 7 When Aya employees refuse to sign revised employment agreements decreasing 8 their pay, “Aya simply proceeds with unilateral pay reductions.” Id. at 9, ¶ 28. “Aya’s 9 pervasive fraud also enables it to compete effectively—albeit unfairly—in the healthcare 10 staffing marketplace.” Id. at 9, ¶ 29. The FAC alleges that “when Aya must compete with 11 other staffing agencies to fill a travel position, it advertises higher pay packages that are 12 more likely to entice travel employees, knowing that it does not intend to pay that amount 13 after the employees begin the assignment.” Id. “In certain parts of the country, like San 14 Diego, Aya’s reach is becoming so great (through use of exclusive contracts and other 15 means) that if a travel employee refuses to complete an assignment at a reduced rate, the 16 employee will be blacklisted from working at facilities in the region.” Id. at 10, ¶ 30. 17 Plaintiffs are all travel nurses who accepted travel work assignments from Aya. See 18 Id. at 3–4, ¶¶ 6–9. O’Dell, a citizen of Indiana, “accepted a travel assignment from Aya to 19 work at a healthcare facility located in California.” Id. at 3, ¶ 6. Bailey, a citizen of 20 Georgia, “accepted a travel assignment from Aya to work at a healthcare facility located in 21 Virginia.” Id. at 3, ¶ 7. Zimmerman, a citizen of Florida, “accepted a travel assignment 22 from Aya to work at a healthcare facility located in New Jersey.” Id. at 3, ¶ 8. Miller, a 23 citizen of Washington, “accepted a travel assignment from Aya to work at a healthcare 24 facility located in California.” Id. at 4, ¶ 9.

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O'Dell v. Aya Healthcare, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/odell-v-aya-healthcare-inc-casd-2023.