On June 22, 2021, the U.S. District Court for the Northern District of Illinois conditionally certified, on the parties’ stipulation, an FLSA collective of salaried disability claims staff in Blackstone v. Dearborn Life Insurance Company, Case No. 1:21-cv-01201. In this disability claims analyst overtime lawsuit, the court granted the parties’ joint motion. Jack Siegel, with co-counsel, represented the workers.
Judge Mary M. Rowland signed the order on June 22, 2021. She found that the joint motion should be, and is hereby GRANTED
. The order conditionally certified the collective for the purpose of sending notice under 29 U.S.C. § 216(b).
In close paraphrase, the 2021 collective reached current and former Dearborn Life Insurance Company employees who, in the last three years, were paid a salary, were classified as exempt under the FLSA, and worked in one of six positions:
STD and LTD refer to short-term and long-term disability claims.
Agreed notice terms. The order approved the parties’ Notice and Consent to Join Form and adopted the schedule in their motion. Notice was to go by first-class mail and email, plus a text message to people without a personal email on file. Emails were to carry a DocuSign link, and workers had 45 days from mailing to return a signed consent form.
This was an agreed order, not a contested ruling. The parties said they agreed in order to save the court’s and their own resources.
Dearborn admitted no wrongdoing and kept its right to seek decertification later. Conditionally certifying the collective did not decide whether anyone was misclassified or whether Dearborn broke the law.
The plaintiffs alleged that Dearborn violated the Fair Labor Standards Act. The order does not say which exemption Dearborn relied on. As general information, a salary and an exempt label do not by themselves make a job exempt.
The administrative exemption, for example, requires pay on a salary basis at or above a set minimum. The primary duty must be office or non-manual work directly related to the management or general business operations of the employer or its customers. It must also include the exercise of discretion and independent judgment on matters of significance.
The parties stipulated to conditional certification as courts in the Seventh Circuit read § 216(b), so the order does not discuss the legal standard. At the time, many courts used a lenient first step to decide whether to send notice.
Some federal appeals courts have since changed this approach — the Fifth Circuit in Swales v. KLLM Transport Services (2021) and the Sixth Circuit in Clark v. A&L Homecare & Training Center (2023). The Seventh Circuit adopted a different approach in Richards v. Eli Lilly & Co. (2025). See how collective action certification works.
This page describes a 2021 court order. The time to join that collective was set by the court in that case. If you have worked in a similar role, the Siegel Law Group can evaluate your own claims.
Have you worked as a salaried, exempt-classified disability claims analyst and put in more than 40 hours in some weeks? A lawyer can review how you were paid. The Siegel Law Group offers a free consultation.
Related rulings: Loomis v. Unum, another overtime case for salaried disability claims staff, and Weeks v. Matrix Absence Management, another case for salaried claims examiners.
Not always. A Labor Department regulation, section 541.203(a), says insurance claims adjusters generally meet the administrative exemption’s duties requirements when their work includes interviewing witnesses, judging coverage, valuing claims, and negotiating. So the answer turns on what an analyst actually does, and the salary test must also be met. The 2021 Dearborn Life order left the exemption question open.
Yes. Dearborn Life and the workers filed a joint Stipulation and Motion, and Judge Rowland granted it on June 22, 2021. They said they agreed to conserve the court’s resources and their own. The insurer made no admission of wrongdoing, and it reserved the right to argue later that the collective should be decertified.
The 2021 order named six positions: STD Claims Associate, STD Claims Analyst, Senior STD Claims Analyst, LTD Claims Associate, LTD Claims Analyst, and Senior LTD Claims Analyst. Members also had to have been paid a salary and classified as exempt under the FLSA in the last three years.
Under the agreed schedule, notice was to go out by first-class mail and by email, with a DocuSign link for signing online. Anyone without a personal email address on the company’s list was to get a text message in place of the email. Workers had 45 days from the mailing date to return a signed consent form.
The Siegel Law Group is a national overtime and wage law firm devoted entirely to representing workers denied overtime pay. Where many firms include wage cases as a small part of a broader employment practice, the Siegel Law Group has built its entire practice around overtime litigation — and the results reflect that commitment: $100M+ recovered for workers, 50+ class and collective action certifications, and 100+ federal lawsuits filed in 27+ federal courts nationwide. Founding attorney Jack Siegel is a Bloomberg BNA contributing author on wage and hour law.
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