In this Fallon Health overtime lawsuit, the Siegel Law Group helped secure two significant victories: FLSA conditional certification and a rare grant of equitable tolling that extended the time period for recovering unpaid overtime. In Gardner v. Fallon Health (D. Mass.), the court delivered rulings that expanded both the scope of the case and the damages available to the workers. The firm has recovered $100M+ for workers nationwide and concentrates in challenging the misclassification of care management and utilization review workers.
The court granted conditional certification, allowing the case to proceed as a collective action under the FLSA. But the more notable ruling was on equitable tolling — the court agreed to pause the FLSA's statute of limitations, effectively extending the time period for which workers could recover damages.
Equitable tolling is rarely granted in FLSA cases. Courts typically require workers to show extraordinary circumstances that prevented them from filing their claims on time. The fact that the court granted tolling here reflects the strength of the workers' arguments and the circumstances of the employer's conduct.
The FLSA imposes strict time limits on overtime claims — two years for non-willful violations, three years for willful violations. Every day that passes without filing can reduce the amount a worker can recover. Equitable tolling preserves those lost wages and ensures workers receive the full compensation they are owed under federal and state overtime laws.
For healthcare workers who may not immediately realize they have been misclassified as exempt, the statute of limitations can be a devastating barrier. This ruling demonstrates that courts have the power to pause the clock when circumstances warrant — and that aggressive advocacy can unlock this remedy even when it is rarely available.
Healthcare workers at Fallon Health who performed care management and utilization review were classified as exempt from overtime under the administrative exemption. They brought claims for unpaid overtime, arguing that their duties were too standardized to qualify for the exemption.
Equitable tolling is a judicially created doctrine that allows courts to extend the statute of limitations when fairness requires it. In FLSA cases, courts consider factors such as whether the employer actively concealed the violation, whether the worker exercised diligence in discovering the claim, and whether extraordinary circumstances prevented timely filing.
If you are a healthcare worker who has been denied overtime pay — even if you are concerned that the statute of limitations may have run on some of your claims — you should still consult with an overtime attorney. Equitable tolling and other legal doctrines may preserve claims that appear to be time-barred. The Siegel Law Group has the experience to evaluate your situation and pursue every available avenue for recovery.
Equitable tolling is a legal doctrine that pauses the statute of limitations when extraordinary circumstances prevented the worker from filing a claim on time. In FLSA cases, it can extend the recovery period beyond the standard two- or three-year limit, allowing workers to recover additional unpaid overtime wages.
Equitable tolling is rarely granted in FLSA cases. Courts apply a high standard, requiring the worker to demonstrate both extraordinary circumstances and reasonable diligence. When it is granted, it typically indicates compelling facts that prevented timely filing.
The FLSA has a two-year statute of limitations for non-willful overtime violations and a three-year statute of limitations for willful violations. Each workweek is treated separately, so the clock runs independently for each pay period. Equitable tolling can extend these deadlines in appropriate cases.
Possibly. Equitable tolling, fraudulent concealment, and other legal doctrines may preserve claims that appear to be time-barred. Additionally, state overtime laws may have longer statutes of limitations than the FLSA. Consult with an overtime attorney to evaluate your specific situation.
Conditional certification is the first step in an FLSA collective action. It allows the court to authorize notice to other potentially affected workers, giving them the opportunity to opt in and pursue their own overtime claims as part of the group.
Class or collective certification allows workers to pool their resources, share legal costs, and present a unified case against the employer's pay practices. It creates leverage for settlement and ensures that all affected workers have the opportunity to participate in the outcome.
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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