In one of the most significant care coordinator overtime rulings in the country, the Siegel Law Group secured three major victories in the Magellan Health overtime lawsuit. In Deakin v. Magellan Health, Inc., Case No. 1:17-cv-00773-MLG-KK (D.N.M.), the court granted summary judgment ruling that Magellan's care coordinators are not exempt from overtime under the administrative exemption, certified a Rule 23 class action under the New Mexico Minimum Wage Act (NMMWA), and denied decertification of the FLSA collective action. The firm has recovered $100M+ for workers nationwide and concentrates in challenging overtime violations in the managed care industry.
This case produced three landmark rulings across six years of litigation:
1. Conditional Certification (October 5, 2018): Chief Judge William P. Johnson granted FLSA conditional certification, allowing the case to proceed as a collective action on behalf of Magellan care coordinators nationwide. Seven declarations from employees in five states supported a company-wide pattern of misclassification. The court authorized notice by email and text message to Magellan's care coordination workforce, which spanned 884 employees across 36 job titles in 31 states plus the District of Columbia.
2. Rule 23 Class Certification and Denial of Decertification (August 14, 2024): Judge Matthew L. Garcia certified a Rule 23(b)(3) class of New Mexico care coordinators under the NMMWA and denied Magellan's motion to decertify the FLSA collective. The class encompassed all current and former care coordinators employed by Magellan in New Mexico from October 1, 2013 to the final date of judgment. The court appointed Attorney Jack Siegel as class counsel. The court found that common questions — particularly whether Magellan's company-wide classification of care coordinators as exempt was lawful — predominated over individual issues.
3. Summary Judgment on the Administrative Exemption (August 28, 2024): In the most decisive ruling, Judge Garcia granted summary judgment for the workers, holding that Magellan's care coordinators are not administratively exempt from overtime under either the FLSA or the NMMWA. The court found that no reasonable jury could conclude otherwise.
Summary judgment on the administrative exemption is rare in overtime litigation. Most exemption cases involve fact-intensive disputes that go to trial. When a court rules as a matter of law that an entire category of workers is non-exempt, it eliminates the employer's primary defense entirely. For care coordinators across the managed care industry, this ruling carries enormous weight.
Judge Garcia's opinion addressed both prongs of the administrative exemption and rejected Magellan's defense on each one:
The "Directly Related" Test: The court found that care coordinators' duties — conducting Comprehensive Needs Assessments (CNAs), generating care plans, and performing Touchpoint evaluations — were "production" work, not administrative work. Care coordinators delivered the care coordination services that Magellan was contracted to provide to Presbyterian Health Plan. They produced the commodity of the business rather than administering the business itself. The court cited Department of Labor opinion letters specifically addressing case managers, which concluded that employees providing day-to-day case management services are not administratively exempt.
The "Discretion and Independent Judgment" Test: The court found that care coordinators did not exercise discretion and independent judgment on matters of significance. CNAs were standardized questionnaires with pre-determined questions. Care coordination levels were assigned by computer algorithm. CCs were subject to close supervision, continual auditing, and penalties for deviations from established protocols. Although CCs exercised some limited discretion in carrying out routine tasks, this was not the kind of meaningful decision-making authority required by the exemption.
Magellan Health is a managed behavioral health company that subcontracts with Presbyterian Health Plan to provide care coordination services to New Mexico Medicaid members under a contract with the New Mexico Human Services Department (HSD). Care coordinators at Magellan administered standardized health risk assessments, conducted CNAs using pre-populated questionnaires, generated care plans based on algorithm-assigned care levels, and followed up with members through Touchpoint phone calls and visits — all governed by HSD Contract requirements that Magellan could not modify without prior government approval.
Magellan classified all care coordinators as exempt from overtime under the administrative exemption, paying them a salary with no overtime compensation despite regular workweeks exceeding 40 hours. The Siegel Law Group filed suit in 2017 and litigated the case through conditional certification, extensive discovery, class certification, and ultimately summary judgment — a seven-year effort that resulted in a complete win on the merits.
If you work as a care coordinator, case manager, or utilization review employee at a managed care company, health plan, or behavioral health organization, this ruling is directly relevant to your situation. Courts have repeatedly found that care management workers who follow standardized protocols, use pre-determined assessment tools, and are subject to employer auditing do not qualify for the administrative exemption — regardless of job title or salary level.
The Deakin ruling is particularly significant because it went beyond certification to a full merits ruling. The court did not simply allow the case to proceed — it ruled definitively that these workers are entitled to overtime.
Summary judgment means the court resolved the key legal issue — whether care coordinators are exempt from overtime — without a trial. The court found the evidence so clearly favored the workers that no reasonable jury could rule otherwise. This is a stronger result than certification alone because it decides the exemption question on the merits.
Based on this ruling and consistent DOL guidance, care coordinators who follow standardized protocols, administer pre-determined questionnaires, and are subject to close supervision are not exempt under the administrative exemption. The exemption requires the exercise of discretion and independent judgment on matters of significance — duties that courts have found care coordinators do not perform.
FLSA conditional certification creates an opt-in collective — workers must affirmatively join. Rule 23 class certification creates an opt-out class — all affected workers are automatically included unless they choose to exclude themselves. Having both gives workers the maximum protection under federal and state overtime laws.
No. Magellan initially raised the professional exemption as a defense but ultimately conceded it did not apply. The exemption analysis focuses on actual job duties, not credentials or job titles. Licensed professionals who follow standardized procedures and lack meaningful decision-making authority may still be entitled to overtime.
Close supervision and auditing is strong evidence that you do not exercise the discretion and independent judgment required for the administrative exemption. In Deakin, the court specifically cited Magellan's extensive audit processes and performance improvement plans as evidence that care coordinators lacked the requisite autonomy.
The FLSA analysis in this ruling — particularly the court's application of the administrative exemption — is persuasive authority for care coordinator cases nationwide. While the Rule 23 class and narrowed FLSA collective were limited to New Mexico, the legal principles apply to care coordinators at managed care companies across the country.
Possibly. The FLSA has a two-year statute of limitations (three years for willful violations), and state overtime laws may have different deadlines. Contact the Siegel Law Group for a free evaluation of your situation.
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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