The Siegel Law Group helped secure a Rule 23 class certification victory in the Matrix Absence Management overtime class action. In Heckle v. Matrix Absence Management, Case No. 21 CV 1463 (VB) (S.D.N.Y.), the court certified a Rule 23(b)(3) class under the New York Labor Law (NYLL) for Telephonic Claims Examiners denied overtime pay at Matrix's Hawthorne, New York office. The firm has recovered $100M+ for workers nationwide and concentrates in challenging overtime violations in the healthcare industry.
On December 14, 2022, Judge Vincent Briccetti certified a Rule 23(b)(3) class under the NYLL and appointed class counsel. The court found that common questions — particularly whether the TCEs' standardized duties qualified for the administrative exemption — predominated over individual issues. The evidence showed that TCEs across the Hawthorne office performed the same core duties under the same constraints, making class treatment appropriate.
The Siegel Law Group brought claims under the NYLL on behalf of TCEs whose work was governed by Matrix Best Practices manuals, decision templates, "cheat sheets," and mandatory supervisor review of all claim denials.
Rule 23 class certification is a powerful tool for overtime workers. Unlike an FLSA collective action — where workers must affirmatively opt in — a Rule 23 class action automatically includes all affected workers unless they choose to opt out. This typically results in far larger classes and greater employer accountability.
This ruling was a powerful illustration of why misclassification claims are well-suited for class treatment: when an employer applies the same exemption classification to an entire group of workers performing the same standardized duties, the legality of that classification is a common question that can be resolved for everyone at once.
Telephonic Claims Examiners at Matrix processed disability and leave-of-absence claims using highly standardized procedures. Despite this tightly controlled work environment, Matrix classified them as exempt from overtime. Under both the FLSA and the NYLL, the administrative exemption requires the exercise of discretion and independent judgment — a standard that is difficult to meet when workers follow scripts, templates, and mandatory review protocols.
Rule 23(b)(3) certification requires that common questions of law or fact predominate over individual questions and that a class action is superior to other methods of adjudication. The misclassification of claims examiners who all perform the same standardized duties under the same policies is a textbook example of a case that satisfies these requirements.
If you are a claims examiner, telephonic reviewer, or disability claims processor who was classified as exempt from overtime, this ruling shows that courts recognize these roles often do not meet the administrative exemption standard. The NYLL and similar state overtime laws may provide additional protections beyond the FLSA, including longer statutes of limitations and different damages calculations.
Rule 23 class certification allows a lawsuit to proceed on behalf of all affected workers as a class. Unlike an FLSA collective action where workers must opt in, a Rule 23 class automatically includes all similarly situated workers unless they affirmatively opt out. This means more workers benefit from the outcome without having to take individual action.
Class certification creates strength in numbers. It allows workers to share the cost of litigation, present common evidence about the employer's pay practices, and hold the employer accountable for its policies affecting all workers — not just the named plaintiffs. Employers facing certified classes often have greater incentive to settle for fair amounts.
In an FLSA collective action, workers must affirmatively opt in by filing a consent form. In a Rule 23 class action, all similarly situated workers are automatically included unless they opt out. Rule 23 classes are typically larger because many workers who would not take the affirmative step of opting in still benefit from being automatically included.
Yes. The New York Labor Law (NYLL) provides overtime protections that may exceed those under the FLSA. New York workers can pursue claims under both federal and state law simultaneously, and the NYLL has a six-year statute of limitations — significantly longer than the FLSA's two- or three-year limit.
Workers are similarly situated when they share common job duties, are subject to the same pay policies, and were classified the same way by the employer. In misclassification cases, if the employer applied a blanket "exempt" classification to a group of workers who all performed standardized duties, those workers are typically found to be similarly situated.
Yes. Former employees can participate in overtime class and collective actions as long as their claims fall within the applicable statute of limitations. Under the FLSA, claims can go back two years (three years for willful violations). Under the NYLL, claims can go back six years.
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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