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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

City of University Park v. University Park Police Ass'n

The case addresses whether the City of University Park is required to compensate its police officers for meal breaks during which they remain on call. Police department employees sued the City for overtime pay, contending that their entire eight-hour shift, including a forty-minute meal break, should be compensable, thereby making their pre-shift "detail" time eligible for overtime. The City countered that meal breaks were not compensable, negating any overtime claim. Applying a two-prong test from Blum v. Great Lakes Carbon Corp., the court assessed whether the time primarily benefited the employee or employer and if it allowed for personal use. The court determined that the meal breaks predominantly benefited the officers and that any interruptions were de minimus. Consequently, the judgment in favor of the police officers was reversed.

Fair Labor Standards ActMeal Break CompensationOn-Call DutyOvertime PayPolice EmploymentPublic Sector Labor LawTexas Civil StatutesWork HoursEmployee BenefitsEmployer Responsibilities
References
16
Case No. MISSING
Regular Panel Decision

Gordon v. Kaleida Health

Six plaintiffs, including registered nurses and respiratory therapists, initiated a putative collective/class action against Kaleida Health and its associated entities. They alleged violations of the Fair Labor Standards Act and New York Labor Law concerning unpaid wages, overtime, and improper meal break deductions. The court addressed four motions: plaintiffs' class certification requests for meal break and rounding policies, and both parties' summary judgment motions. The judge denied all of the plaintiffs' motions and granted the defendants' motions, striking the rounding class certification, denying the meal break class certification, and largely granting summary judgment to Kaleida regarding certain NYLL claims for three plaintiffs. The court found no evidence of a uniform system-wide policy for wage violations and upheld the employer's right to delegate reporting procedures for missed meal breaks.

Fair Labor Standards ActNew York Labor LawClass ActionWage and Hour DisputeOvertime PayMeal Break PolicyRounding PolicySummary JudgmentClass CertificationHourly Employees
References
59
Case No. MISSING
Regular Panel Decision

Fengler v. Crouse Health Foundation, Inc.

The case involves two named plaintiffs, Michelle Fengler and Marianne Meyers, along with over a hundred other employees, who allege that Crouse Health Hospital, Inc. violated the Fair Labor Standards Act by failing to properly compensate hourly employees due to an automatic meal break deduction policy. Plaintiffs contend that chronic understaffing and patient care demands required employees to work during meal breaks without pay. The court, presided over by Magistrate Judge David E. Peebles, granted preliminary certification for a collective action, but limited the class to current and former hourly employees of Crouse Hospital with direct patient care responsibilities who were subject to automatic meal break deductions and worked through unpaid breaks in the last three years. The court also partially granted discovery requests for employee names and addresses, while denying requests for more private information, and ordered the parties to agree on a notice for potential opt-in plaintiffs.

Fair Labor Standards ActCollective ActionMeal Break DeductionUnpaid WagesHourly EmployeesPatient Care ResponsibilitiesPreliminary CertificationWage and Hour DisputeUnderstaffingJudicial Discretion
References
24
Case No. M2011-00109-SC-Rll-CV
Regular Panel Decision
Mar 13, 2014

Aundrey MEALS Ex Rel. William MEALS v. FORD MOTOR COMPANY

A six-year-old boy suffered permanent paralysis and other severe injuries in a car crash caused by a defective seatbelt in a Ford vehicle. His mother sued Ford, and a jury awarded $43.8 million in compensatory damages. The Court of Appeals reduced this award, but the Supreme Court reversed the appellate court's decision, reinstating the jury's original verdict. The Supreme Court found the jury's assessment of damages was supported by material evidence and was within the range of reasonableness, emphasizing judicial deference to jury verdicts in such catastrophic injury cases.

Car accidentSpinal cord injuryParaplegiaProduct liabilityDefective designSeatbelt defectCompensatory damagesRemittiturJury verdictAppellate review
References
64
Case No. MISSING
Regular Panel Decision
Nov 29, 2011

Hamelin v. Faxton-St. Luke's Healthcare

Plaintiffs Dawn Hamelin, Rakiesha Griffin, and Julie Flint brought a collective action against Faxton-St. Luke’s Healthcare and other entities, alleging violations of the FLSA, ERISA, and NYLL related to uncompensated meal breaks and pre/post-shift work. The court granted defendants' motion for partial summary judgment, dismissing eight opt-in plaintiffs who did not claim to have worked through meal breaks without compensation. Plaintiffs' motion for class certification was granted for Subclass I, the 'Meal Break Deduction Class,' finding that common questions predominated and a class action was the superior method. However, certification was denied for Subclass II (pre/post-shift work) due to lack of commonality predominance and Subclass IV (ERISA claims) due to insufficient evidence. The court also appointed Thomas & Solomon LLP as class counsel.

Fair Labor Standards ActEmployee Retirement Income Security ActNew York Labor LawClass ActionCollective ActionMeal Break DeductionsUnpaid WagesSummary JudgmentClass CertificationRule 23
References
57
Case No. MISSING
Regular Panel Decision

Meyers v. Crouse Health System, Inc.

Named plaintiff Marianne Meyers brought this action against Crouse Health Hospital, Inc. and other entities, alleging violations of FLSA, ERISA, and NYLL regarding uncompensated work time, specifically concerning automatic meal break deductions and other pay policies. Defendants moved for partial summary judgment to dismiss eight opt-in plaintiffs from the FLSA collective action, while plaintiff moved to certify NYLL and ERISA claims as a class action. The court granted defendants' motion, dismissing seven opt-in plaintiffs who admitted they did not work through meal breaks without compensation, finding them outside the conditionally certified FLSA class. The court also granted class certification for Subclass I (Meal Break Deduction Class) under Rule 23(b)(3) but denied certification for Subclass II (Pre and Postliminary Work Class) due to a lack of numerosity, and for Subclass IV (ERISA Class) due to insufficient evidence. Thomas & Solomon LLP was appointed as class counsel for Subclass I, and the matter was referred back to Magistrate Judge David Peebles for further pretrial proceedings, with the court also affirming the exercise of supplemental jurisdiction over the NYLL claims.

FLSA Collective ActionERISA Class ActionNYLL Wage and HourClass CertificationMeal Break DeductionsUncompensated WorkSummary Judgment GrantedSupplemental JurisdictionRule 23 PrerequisitesNumerosity Challenge
References
55
Case No. MISSING
Regular Panel Decision
Apr 14, 1980

In re the Claim of Cruz

The claimant, an assistant engineer at a nursing home, was discharged for leaving the premises for a meal break in violation of employer policy, despite a prior warning. The employer required the claimant to remain on-site during breaks as he worked alone on a night shift and needed to be available for emergencies. The Unemployment Insurance Appeal Board initially found the employer's rule invalid based on its interpretation of Labor Law § 162 (subd 4), determining the claimant's actions did not constitute disqualifying misconduct. However, the Appellate Division reversed this decision, holding that Labor Law § 162 (subd 4) does not dictate the location of a meal break and that the employer's policy, especially with compensated breaks, was reasonable. The case was remitted to the Board for further proceedings.

MisconductUnemployment InsuranceMeal Break PolicyEmployer RulesStatutory InterpretationLabor LawAdministrative Law JudgeAppeal BoardNursing Home EmployeeTermination
References
4
Case No. MISSING
Regular Panel Decision
May 30, 2000

Stein v. Beaver Concrete Breaking Co.

Stuart Stein appealed an order from the Supreme Court, Kings County, which granted summary judgment to Beaver Concrete Breaking Co., Inc., dismissing his personal injury complaint. The appellate court affirmed the lower court's decision, citing that a person can have both a general and special employer for Workers' Compensation Law purposes. Since Stein received workers' compensation benefits from his special employer, JAB Construction, Inc., and Beaver was determined to be his general employer, Beaver was shielded from the lawsuit under Workers' Compensation Law §§ 10, 11, and 29 [6].

Personal InjurySummary JudgmentWorkers' Compensation LawGeneral EmployerSpecial EmployerAppellate ReviewEmployer LiabilityStatutory InterpretationTort LawNew York Law
References
3
Case No. MISSING
Regular Panel Decision

McGlone v. Contract Callers, Inc.

Plaintiff Michael McGlone initiated a Fair Labor Standards Act (FLSA) action against Contract Callers, Inc. (CCI), Michael McGuire, and William Tim Wertz, alleging unpaid overtime for work performed before and after recorded workdays and during meal breaks. McGlone sought conditional certification for a nationwide collective action of Field Service Representatives (FSRs), asserting a common policy of wage violations, including uncompensated preparatory and concluding tasks, and automatic meal break deductions despite working through them. The court applied a two-step analysis for FLSA collective actions, focusing on the lenient "notice stage" standard. While the plaintiff claimed company-wide misconduct, his evidence for a nationwide class was deemed insufficient, relying primarily on "information and belief." Consequently, the court denied conditional certification for a nationwide class but granted it for FSRs employed in CCI's New York Division, where McGlone demonstrated direct personal knowledge of the alleged violations and supervisory directives. Additionally, the statute of limitations was equitably tolled as of the motion's filing date due to the court's processing time.

FLSACollective ActionConditional CertificationOvertime PayWage ViolationsMeal BreaksUncompensated WorkField Service RepresentativesEquitable TollingNew York Division
References
28
Case No. MISSING
Regular Panel Decision

Drew v. Tappan Co.

The employee, Jack Drew, sustained an injury on the Tappan Company's property while walking to his car during a lunch break to retrieve his meal. The company's parking was inadequate, leading employees to park on a nearby gravel road and use a worn path across company land. The trial court ruled that Drew's injury was compensable under worker's compensation, a decision which the employer and its insurance carrier appealed. The appellants argued that the injury did not arise out of and in the course of employment, citing precedents related to injuries sustained en route to or from work. However, the Supreme Court distinguished these cases, categorizing Drew's situation as an "on premises-lunch break" injury, which is typically compensable when occurring on the employer's premises during a designated break period. Consequently, the Court affirmed the trial court's judgment, finding sufficient material evidence to support the compensability of the injury.

worker's compensationpremises liabilitylunch break injuryscope of employmentarising out of employmentcourse of employmentcompensabilityTennessee lawworkplace injuryappeal
References
11
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