U.S. Department of Labor v. Constant Care Home Health Services, LLC

CourtDistrict Court, S.D. Ohio
DecidedJune 27, 2025
Docket3:24-cv-00078
StatusUnknown

This text of U.S. Department of Labor v. Constant Care Home Health Services, LLC (U.S. Department of Labor v. Constant Care Home Health Services, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
U.S. Department of Labor v. Constant Care Home Health Services, LLC, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

LORI CHAVEZ-DEREMER, Secretary of : Labor, United States Department of Labor, : : Case No. 3:24-cv-78 Plaintiff, : : Judge Thomas M. Rose v. : : CONSTANT CARE HOME HEALTH : SERVICES, LLC, et al., : : Defendants. ______________________________________________________________________________

ENTRY AND ORDER DENYING PLAINTIFF’S UNOPPOSED MOTION FOR RECONSIDERATION (DOC. NO. 18) AND GRANTING PERMANENT INJUNCTION PURSUANT TO 29 U.S.C. § 217 ______________________________________________________________________________

Presently before the Court is Plaintiff’s Unopposed Motion for Reconsideration (“Motion”) (Doc. No. 18) of Plaintiff Lori Chavez-Deremer, Secretary of Labor, United States Department of Labor, (“Plaintiff”). On April 29, 2025, Plaintiff and Defendants Constant Care Home Health Services, LLC, Duncan Muchiri, and David Mbugua (collectively, “Defendants”) filed a Consent Order and Judgment (“Consent Order”), seeking judicial approval of the terms of the settlement of Plaintiff’s claims under the Fair Labor Standards Act of 1938, as amended, 29 U.S.C. § 201, et seq. (“FLSA”). On May 16, 2025, the Court issued its Entry and Order Denying Consent Order and Judgment (“Order”) on the basis that the Court does not have the authority under § 216(c) or any binding precedent to approve settlement agreements. (Doc. No. 17.) Plaintiff now moves for reconsideration of that Order. For the reasons explained below, the Court DENIES Plaintiff’s Unopposed Motion for Reconsideration. The Court further GRANTS Plaintiff a permanent injunction pursuant to 29 U.S.C. § 217. District Courts have the authority under common law and Fed. R. Civ. P. 54(b) to reconsider an interlocutory order prior to final judgment. Rodriguez v. Tenn. Laborers Health & Welfare Fund, 89 F. App’x 949, 959 (6th Cir. 2004). However, “‘courts will [only] find

jurisdiction for reconsidering interlocutory orders where there is (1) an intervening change of controlling law; (2) new evidence available; or (3) a need to correct a clear error or prevent manifest injustice.’” Dunham v. Sheets, No. 1:13-cv-226, 2015 U.S. Dist. LEXIS 61330, at *4, 2015 WL 2194755, at *2 (S.D. Ohio May 11, 2015) (quoting Louisville/Jefferson Cnty. Metro Gov’t v. Hotels.com, L.P., 590 F.3d 381, 389 (6th Cir. 2009)). The basic premise of Plaintiff’s Motion is that the Court’s Order was a manifest injustice because it would prevent the Department of Labor from obtaining the prospective injunctive relief to which it believes it is entitled under 29 U.S.C. § 217. (Doc. No. 18 at PageID 70-73.) To do so, in Plaintiff’s view, would undermine the purpose of the statute, which is remedial in nature. (Id.) Plaintiff further cites to other cases in the Southern District of Ohio where injunctions

pursuant to § 217 have been granted or where consent decrees have been entered. (Id.) Plaintiff ultimately argues, “[a] continuing refusal to enter the April 29, 2025, proposed Consent Judgment and Order would deny the Secretary her statutory entitlement to enjoin Defendants from future violations of the Act and her entitlement to enjoin Defendants to pay all of the back wages owed, as only the Court has the authority to enjoin parties.” (Id. at PageID 72.) As a point of order, Plaintiff does not have a statutory entitlement to an injunction under § 217 by virtue of being the Secretary of Labor. Instead, § 217 states, “[t]he district courts… shall have jurisdiction, for cause shown, to restrain violations of section 215 of this title, including in the case of violations of section 215(a)(2) of this title the restraint of any withholding of payment of minimum wages or overtime compensation found by the court to be due to employees under this chapter….” 29 U.S.C. § 217 (emphasis added). Indeed, at least one of the cases cited by Plaintiff makes clear that the burden of proving an injunction is warranted rests with Plaintiff. Dept. of Labor v. Americare Healthcare Servs., 762 F. Supp. 3d 666, 698 (S.D. Ohio Jan. 9, 2025).

Moreover, Plaintiff’s cited cases demonstrate that in granting a permanent injunction the Court must consider: “(1) the previous conduct of the employer; (2) the current conduct of the employer; and (3) the dependability of the employer’s promises for future compliance.” Su v. Halo Homecare Services, LLC, No. 1:20-cv-744, 2023 WL 4286494, at *9 (S.D. Ohio June 30, 2023) (citing Reich v. Petroleum Sales, Inc., 30 F.3d 654, 657 (6th Cir. 1994)); Americare Healthcare Servs., 762 F. Supp. 3d at 698. Plaintiff’s Consent Order, unaccompanied by a motion, does nothing to demonstrate just cause for an injunction beyond the agreement of Defendant to comply with the terms agreed upon. It would seem Plaintiff expected this Court to act as a rubber stamp to their agreement. Consent decrees1 occupy an unusual place in the law. “Unlike a settlement agreement, a

consent decree entered in federal district court draws upon the Article III power, and the decree invokes the court’s continuing jurisdiction to ensure compliance with its order until the parties have fulfilled their obligations.” Evoqua Water Tech., LLC. v. M.W. Watermak, LLC, 940 F.3d 222, 237 (6th Cir. 2019) (J. Bush concurring) (citing Williams v. Vukovich, 720 F.2d 909, 920 (6th Cir. 1983)). Therefore, in entering a consent decree the court is not merely acknowledging the parties settlement, but complying with an “independent judicial interest” that puts the weight of the court behind the agreement. See Evoqua Water Tech., 940 F.3d at 238 (J. Bush concurring).

1 Plaintiff attempts to distinguish Gilstrap by citing to a portion of a footnote in that decision. (Doc. No. 18 at PageID 71.) Plaintiff cites to a small fraction of the entire footnote, however, and fails to note Judge Cole’s conclusion, “the question whether a district court may enter a consent decree to resolve an FLSA case is for another day, as no party seeks such relief here.” Gilstrap v. Sushinati LLC, 734 F. Supp. 3d 710, n. 8 (S.D. Ohio 2024). Consequently, the Court is obligated to exercise its independent judgment to determine whether it has the authority to approve a party’s settlement and whether it would be appropriate to do so. Thus, the Court circles back to the thorny issue of what § 216(c) does and does not provide for as it relates to the non-injunctive portions of the Consent Order. As previously stated, the

statute, Supreme Court precedent, and Sixth Circuit precedent do not provide for judicial approval of FLSA settlements. (See Doc. No. 17.) The Court is consequently unable to approve the portions of the Consent Order that serve no prospective relief and operate as nothing more than a typical settlement agreement. (See Doc. No.

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