Torri Houston v. St. Luke's Health System, Inc., No. 22-1862 (8th Cir. 2023)
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Plaintiff, a former employee, sued on behalf of herself and similarly situated employees, claiming that St. Luke’s violated the Fair Labor Standards Act’s (“FLSA”) overtime provisions by failing to fully compensate employees for work performed. She also brought an unjust-enrichment claim under state law. The district court certified two classes with different lookback periods: (1) an FLSA collective comprised of employees who worked for St. Luke’s between September 2016 and September 2018, 1 and (2) an unjust-enrichment class comprised of all employees who worked for St. Luke’s in Missouri between April 2012 and September 2018. Houston also asserted individual claims, one under the Missouri Minimum Wage Law, and one for breach of her employment contract. The district court granted summary judgment to St. Luke’s on all claims.
The Eighth Circuit vacated and remanded. The court explained that Plaintiff has raised a genuine dispute that the rounding policy does not average out over time. The court explained that no matter how one slices the data, most employees and the employees as a whole fared worse under the rounding policy than had they been paid according to their exact time worked. Here, the rounding policy did both. It resulted in lost time for nearly two-thirds of employees, and those employees lost more time than was gained by their coworkers who benefited from rounding. The court concluded that the employees have raised a genuine dispute that the rounding policy, as applied, did not average out over time. The district court, therefore, erred in granting summary judgment on the FLSA and Missouri wage claims.
Court Description: [Gruender, Author, with Arnold and Kelly, Circuit Judge] Civil case - Fair Labor Standards Act. The district court erred in granting the hospital's motion for summary judgment concerning its rounding policy on timekeeping for its employees shifts because plaintiff presented sufficient evidence to raise a genuine dispute as to whether the policy resulted in systematic undercompensation over time in violation of the FLSA and Missouri wage law; the judgment is vacated and the matter is remanded for further proceedings consistent with the opinion.
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