Part of our managed care overtime cases →
In Slaughter v. Caidan Management Co., No. 1:17-cv-05846 (N.D. Ill.), care management employees alleged that they were paid a salary and classified as exempt, with no overtime for hours over 40. On July 5, 2018, Magistrate Judge Jeffrey T. Gilbert granted their motion for step-one notice in part (Doc. 57). Jack Siegel appeared pro hac vice for the workers.
The named plaintiff and eighteen other current or former employees filed declarations. They worked for health plans the defendant managed, Meridian Health Plan of Michigan and Meridian Health Plan of Illinois, under titles such as Care Coordinator, Community Care Coordinator, Utilization Care Coordinator and Community Health Outreach Worker. They said they performed five core duties: data collection, data entry, care utilization, plan education and care coordination.
The court held that the plaintiffs had met their burden of a “modest factual showing” for seven job titles: Care Coordinator, Community Care Coordinator, Community Health Outreach Worker, Utilization Care Coordinator, Care Coordinator Support Specialist, Medicare/Medicaid Benefit Care Coordinator and Inpatient Review Nurse. Notice covered employees in both Michigan and Illinois. The court did not authorize notice to several other titles for which there were no declarations.
Conditional certification is an early step that lets notice go out. It is not a finding that anyone was misclassified or that the employer broke the law.
As general information, the FLSA requires overtime for hours over 40 in a workweek unless the employer proves an exemption. The administrative exemption requires, among other things, a primary duty that includes the exercise of discretion and independent judgment on matters of significance. At the time of this 2018 order, courts in the Northern District of Illinois used a two-step approach; the Seventh Circuit adopted a different approach in Richards v. Eli Lilly & Co. (2025).
This page describes a 2018 court order. The time to join that collective was set by the court in that case.
In a later case, Del Toro v. Centene Management Company, a federal court in Missouri conditionally certified a seven-state collective of salaried Care Management Employees.
Conditional certification allows a case to proceed as a collective action, meaning other similarly situated managed care workers can join the lawsuit. Notice is sent to potential opt-in plaintiffs, giving them the opportunity to pursue their own claims for unpaid overtime as part of the group.
The FLSA collective action process has two stages. At the first stage (conditional certification), the court decides whether to authorize notice to potential opt-in plaintiffs. At the second stage (decertification), the employer challenges whether the workers are truly similarly situated.
It depends on the actual duties. The administrative exemption requires the exercise of discretion and independent judgment, and the employer must prove it applies. A job title or a salary does not settle the question.
After conditional certification, the court authorizes notice to be sent to potential opt-in plaintiffs. Workers then have a set period to file consent forms. After the opt-in period, the case proceeds through discovery, and the employer typically moves for decertification. If the collective survives, the case moves toward summary judgment or trial.
Siegel Law Group PLLC concentrates in unpaid overtime cases under the FLSA and state wage laws. The firm has filed more than 100 federal overtime cases, obtained 50+ class and collective certifications in 20 federal judicial districts across 15 states, and recovered more than $100 million for workers. It has never represented an employer in a wage case. Free consultation. Contingency fee: we advance case costs, and they are repaid from any recovery. No recovery, no fee and no costs. Phone: (214) 790-4454 | Email: [email protected]
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"Certified" means a judge agreed the case could go forward for a group of workers at once, not just the one person who filed it. It is a step in the case, not the end of it.
Attorney advertising. Case information shown is taken from public court filings and court-approved settlements in cases this firm brought. Every case turns on its own facts and on the law of the court where it is heard. Prior results do not guarantee a similar outcome, and a certification or ruling in one case does not guarantee the same result in another. Nothing on this page is legal advice, and reading it or sending a message does not create an attorney-client relationship.
Jack L. Siegel of Siegel Law Group PLLC, Dallas, Texas, is responsible for the content of this page. He appears in federal courts in other states by admission to those courts or by leave of court, and is not licensed in every state shown in this list.
