Piddock v. Community Residence Corporation

CourtDistrict Court, E.D. Michigan
DecidedJuly 25, 2025
Docket5:22-cv-10715
StatusUnknown

This text of Piddock v. Community Residence Corporation (Piddock v. Community Residence Corporation) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Piddock v. Community Residence Corporation, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Sheila Denise Piddock,

Plaintiff, Case No. 22-10715

v. Judith E. Levy United States District Judge Community Living Network, Mag. Judge Curtis Ivy, Jr. Defendant.

________________________________/

OPINION AND ORDER GRANTING DEFENDANT COMMUNITY LIVING NETWORK’S MOTION FOR SUMMARY JUDGMENT [32]

Plaintiff Sheila Denise Piddock brings suit against Defendant Community Living Network (“CLN”) under the Fair Labor Standards Act (“FLSA”). Before the Court is Defendant’s motion for summary judgment. (ECF No. 32.) The motion is fully briefed. (ECF Nos. 34, 35.) On December 5, 2024, an in-person hearing was held, and oral argument was heard on Defendant’s motion. For the reasons set forth below, Defendant’s motion for summary judgment is granted. I. Background Plaintiff has two sons with developmental disabilities who were

enrolled in “self-directed” Medicaid services. Those who use “self- directed” Medicaid services are able to choose the individuals who provide them with care,1 and these caregivers are paid with Medicaid

funds. (ECF No. 32, PageID.1348–1349; ECF No. 34, PageID.1906–1907.) When an individual who needs care (a “care recipient”) enrolls in

“self-directed” Medicaid services, they (and their guardian, when applicable) meet with their local Community Mental Health (“CMH”) agency.2 At this meeting, they develop an “individualized plan of service”

(“Plan”), which addresses the care recipient’s individual needs. They then create a budget made up of Medicaid funds for the care recipient based on their Plan. (ECF No. 34-2, PageID.1936, 1943–1944, 1955, 1974; ECF

No. 34-3, PageID.1980.) For the caregiver to be paid with Medicaid funds, the care recipient must work with a “fiscal intermediary” or “fiscal management entity,” which is a nonprofit that contracts with their CMH

1 If a care recipient has a guardian, that guardian makes decisions regarding the recipient’s self-directed Medicaid services.

2 A CMH is a county-based government agency. to be “the fiduciary for drawing down Medicaid funds and paying out payroll” to their caregivers. (ECF No. 34-2, PageID.1934, 1944, 1955;

ECF No. 34-9, PageID.2147.) Lifeways is the CMH agency for Jackson County, Michigan. (ECF No. 34-5, PageID.1841; ECF No. 34-2, PageID.1936.) For the relevant

time, Lifeways has only contracted with a single Fiscal Intermediary: Defendant Community Living Network. This means that Lifeways care

recipients who used self-directed Medicaid services were required to use Defendant as their fiscal intermediary. (Id.) After Lifeways establishes a care recipient’s Plan and budget,

Defendant meets with the care recipient (or their guardian) and they complete a “wage worksheet” together to determine the caregiver’s hours and wages based on the care recipient’s Medicaid budget and applicable

wage and overtime laws. (ECF No. 34-9, PageID.2149; ECF No. 34-2, PageID.1947.) Defendant tracks and reports training that caregivers are required to complete under Medicaid, maintains HR records of

caregivers, conducts an annual criminal background check on caregivers, and prepares and issues paychecks. (ECF No. 34-3, PageID.1978–1979, 1981, 1988, 1990, 1994; ECF No. 34-6, PageID.2111; ECF No. 34-9, PageID.2149.) Defendant does not provide training, does not supervise caregivers on-site, and does not discipline caregivers. (ECF No. 34-2,

PageID.1951–1952; ECF No. 34-3, PageID.1985, 1992; ECF No. 32-4, PageID.1853–1854.) Here, Plaintiff was a caregiver to her sons Martin and Matthew,

and was paid for her caregiving with Medicaid funds through this program. (ECF No. 32-4, PageID.1835.) Plaintiff claims that Defendant

was her employer and violated the FLSA because it failed to pay her overtime wages between December 16, 2019 and August 15, 2022. (ECF No. 34, PageID.1903 (citing ECF No. 34-5).) Defendant responds that it

is not liable for the failure to pay overtime wages because it is not an employer under the FLSA. II. Legal Standard

Summary judgment is proper when “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). The Court may not

grant summary judgment if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The Court “views the evidence, all facts, and any inferences that may be drawn from the facts in the light most favorable to the nonmoving party.” Pure Tech Sys., Inc. v. Mt.

Hawley Ins. Co., 95 F. App’x 132, 135 (6th Cir. 2004) (citing Skousen v. Brighton High Sch., 305 F.3d 520, 526 (6th Cir. 2002)). III. Analysis

Plaintiff brings one count, alleging that Defendant violated the FLSA when it failed to “compensate Plaintiff[] at time-and-one-half times

[her] regular rate for any hours worked over forty (40) hours in a workweek.” (ECF No. 3, PageID.23–24.) The sole dispute in Defendant’s motion for summary judgment is whether Defendant is an “employer”

pursuant to the FLSA and, thus, can be held liable for violations of the FLSA.3 The FLSA defines “employer” as “any person acting directly or

indirectly in the interest of an employer in relation to an employee . . . .”

3 Plaintiff believes Defendant is a “joint” or “third-party” employer. (ECF No. 34, PageID.1916–1917 (“The ultimate issue in this matter is whether Defendant is Plaintiff’s third-party employer such that, pursuant to the Home Care Final Rule, it cannot assert the companionship exception under the FLSA . . . .”).) Meanwhile, Defendant argues it is not an employer at all and denies that it has ever “asserted it is exempt from paying overtime under the ‘companionship exception.’” (ECF No. 35, PageID.2186; ECF No. 32, PageID.1354–1355.) The Court clarifies that it need not address whether Defendant violated the Home Care Rule and limits its analysis to whether Defendant is an employer pursuant to the economic reality test. 29 U.S.C. § 203(d). “While the [FLSA] does define the terms ‘employee,’ ‘employer,’ and ‘employ,’ the definitions are exceedingly broad and

generally unhelpful.” Solis v. Laurelbrook Sanitarium & Sch., Inc., 642 F.3d 518, 522 (6th Cir. 2011) (citations omitted). Courts in the Sixth Circuit use the “economic reality” test to determine whether the

relationship between the parties “is one of employment or something else.” Id. (citing Tony & Susan Alamo Found. v. Sec’y of Labor, 471 U.S.

290, 301 (1985)); see also Acosta v. Off Duty Police Servs., Inc., 915 F.3d 1050, 1055 (6th Cir. 2019) (“To determine whether a worker fits within this expansive definition, we must look to see whether [the] worker, even

when labeled as an ‘independent contractor,’ is, as a matter of ‘economic reality,’ an employee.”).4

4 To the extent Defendant argues that the Court’s prior decision denying Plaintiff’s renewed motion for court-facilitated notice indicates that Defendant’s motion for summary judgment should also be granted (ECF No. 32, PageID.1354; ECF No. 35, PageID.2182–2183), the Court disagrees.

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