Tiffany Sparks v. TLC House and Residential Services, LLC, et al.

District Court, S.D. Indiana·Decided April 14, 2026·No. 1:25-cv-02034·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

TIFFANY SPARKS, ) ) Plaintiff, ) ) v. ) No. 1:25-cv-02034-JPH-MJD ) TLC HOUSE AND RESIDENTIAL SERVICES, ) LLC, et al., ) ) Defendants. )

ORDER APPROVING COLLECTIVE ACTION NOTICE

This matter is before the Court on Plaintiff's motion entitled Motion for Approval of Notice of Approval of Collective Action, Class Definition and Contact Information for Potential Class Members, [Dkt. 39], and Plaintiff's Motion to Approve Notice of Collective Action and Opt-In Consent Form, How Notice Is Served, [Dkt. 45], which is essentially a supplement to the first motion. For the reasons and to the extent set forth below, the motions are GRANTED. I. Background As relevant to the instant motions, Plaintiff alleges in her Amended Complaint, [Dkt. 36], that Defendants violated the overtime provisions of the Fair Labor Standards Act ("FLSA"), 29 U.S.C. § 207, by failing to pay certain caregiver employees1 the required overtime premium when they worked more than forty hours in a workweek. Plaintiff intends to seek certification of

1 The employees in question "provided home and community-based services and/or attendant care services ('waiver services') to a person ('Medicaid waiver recipient') receiving waiver services from [Defendant] TLC under the Indiana Family and Social Services Administration's ('FSSA') Medicaid Waiver Program." [Dkt. 49 at 3.] "FSSA bills TLC as the Medicaid approved service provider for these waiver services and TLC, as the third-party employer, pays caregivers for the hours worked performing these services." Id. Defendants originally treated the caregivers as independent contractors, but at some point began treating them as employees. a collective action pursuant to the FLSA. The first step in doing so is to send notice to the potential plaintiffs to give them the opportunity to join the case as plaintiffs. In response to the instant motions, Defendants did not oppose sending notice to potential plaintiffs, but took issue with some of the provisions in Plaintiff's proposed notice. See [Dkt. 49] (Defendants' Response);

[Dkt. 63] (Defendants' Surreply). In her Reply, Plaintiff conceded some of Defendants' points. The Court then instructed Plaintiff to file a revised proposed notice and also instructed Defendants to file their own proposed notice, so that the Court would have before it proposed notices that reflected the parties' positions with regard to the remaining arguments. [Dkt. 60.] The parties have done so. See [Dkt. 62] (Plaintiff's revised proposed notice); [Dkt. 64] (Defendants' proposed notice). The Court then held a hearing to allow the parties to address the differences between their proposed notices. See [Dkt. 68]. During the hearing, the Court provided the parties with its own proposed collective class definition; 2 the parties had no objection to the Court's proposed definition, so that is the definition used in the Notice approved herein.

II. Discussion The Court will now address the remaining disputes between the parties.3 A. Relevant Time Period First, the parties disagree on the relevant time frame for the collective class definition to be set forth in the Notice. Plaintiff proposes that the Notice be sent to "all present and former

2 Of course, an FLSA collective action is not a class action. Nonetheless, the group of people to whom notice is sent pursuant to the FLSA is commonly referred to as the "collective class." The parties use the term in their briefs, and the Court will use the term here as well. 3 The Court notes that Defendants raised an issue regarding adding language to Section 7 of the Notice, but they did not include any such language in their proposed notice. Accordingly, the Court finds that they have waived that issue. caregiver employees of TLC House and Residential Services, LLC who worked 40 or more hours in a workweek and were employed on or after April 1, 2022." [Dkt. 62.] Defendants propose that the Notice be sent to the following: "All full-time present and former caregiver employees of TLC House and Residential Services, LLC who worked over 40 hours in a

workweek and were not paid the overtime premium for those hours on or after October 6, 2022." [Dkt. 64.] Defendants choose October 6, 2022, because that is three years before the date this case was filed and FLSA claims are subject to either a two-year or three-year statute of limitations depending on whether a willful violation is found. Plaintiff argues that April 1, 2022, is appropriate for the Notice because that is the date Defendants became subject to the FLSA, and Plaintiff believes that the statute of limitation is subject to equitable tolling because there is (disputed) evidence that Defendants failed to post the notice of employees' rights required by the FLSA until sometime in late 2022 or early 2023. Defendants argue—correctly—that whether equitable tolling may be applied to extend the statute of limitation for any particular plaintiff's claim is an individualized determination that

likely cannot be made on a classwide basis. Defendants are incorrect in suggesting that means that the Notice cannot include putative plaintiffs whose claims will be time barred if they are not entitled to equitable tolling. Rather, "[f]rom filing to judgment, 'collective actions permit individualized claims and individualized defenses.'" Vanegas v. Signet Builders, Inc., 113 F.4th 718, 725 (7th Cir. 2024) (quoting Canaday v. Anthem Cos., Inc., 9 F.4th 392, 403 (6th Cir. 2021)). To secure notice, "a plaintiff must produce some evidence suggesting that they and the members of the proposed collective are victims of a common unlawful employment practice or policy." Richards v. Eli Lilly & Co., 149 F.4th 901, 913 (7th Cir. 2025), cert. denied, 2026 WL 79908 (U.S. Jan. 12, 2026). Plaintiff does not have to demonstrate that the claims of every member of the putative collective action are identical. "The fact that some potential plaintiffs may need to invoke equitable tolling to defeat Defendants' statute of limitations argument does not negate the fact that they are similarly situated to Plaintiff (i.e. victims of a common policy or plan that violated the law)." Pizano v. Big Top Party Rentals, LLC, 2018 WL 2193245, at *5

(N.D. Ill. May 14, 2018) (citing Cisneros v. Jinny Beauty Supply Co., 2004 WL 524482, at *1 (N.D. Ill. Feb. 6, 2004) (rejecting defendants' argument that plaintiff was not "'similarly situated' to plaintiffs who would invoke equitable tolling")). Therefore, like the courts in Pizano and Cisneros, the Court finds that it is appropriate for the Notice to include potential plaintiffs whose claims depend on the successful invocation of equitable tolling. B. Defendants' proposed language in Paragraph 4 Paragraph 4 of Plaintiff's proposed Notice reads as follows: 4. ELIGIBILITY TO PARTICIPATE IN THE LAWSUIT.

Plaintiff brings this collective action on behalf of all alleged current and former Nonexempt Employees who Plaintiff claims worked over 40 hours in a week for TLC during the Relevant Time Period.

If you meet this description, you may have the right to join and participate in this lawsuit to assert a potential claim for alleged unpaid overtime premiums. It is entirely your own decision whether to join this lawsuit.

You may also contact an attorney of your choice. If you do not wish to be a part of the lawsuit, you do not need to do anything. This decision to join is entirely yours.

[Dkt.

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Tiffany Sparks v. TLC House and Residential Services, LLC, et al., (S.D. Ind. 2026).

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