Healthcare Worker Denied Overtime Due to Lack of Funds

In the case of Butterfield v. University Physicians & Surgeons, Inc., Michelle Butterfield filed a lawsuit against University Physicians & Surgeons, also known as Marshall Health, for violating the Fair Labor Standards Act (FLSA). Butterfield claimed she and other employees regularly worked more than 40 hours per week without receiving the required overtime pay.

Butterfield specifically mentioned that she reported overtime hours to Marshall Health but they failed to compensate her for the extra hours. Marshall Health claimed it couldn’t afford to pay for overtime. As a result, Butterfield filed the lawsuit on behalf of herself and other healthcare employees who were paid on an hourly basis at Marshall Health during the three years before the lawsuit.

Marshall Health filed a motion to dismiss the lawsuit, by arguing that the complaint did not state a claim under the FLSA. However, the court determined that Butterfield’s allegations were enough to support a plausible claim for overtime pay. It noted that she provided specific facts about reporting overtime hours and being denied payment based on a lack of funds.

As a result, the court denied Marshall Health’s motion to dismiss the case, which allowed Butterfield’s claim and potential class action to proceed. The court directed the parties to move forward with discovery to gather more information and determine the details.

Key lessons from this case:
  • Employees can file for unpaid overtime claims up to 3 years prior if their employer is found to willfully violate overtime laws.
  • An employee needs to provide sufficient evidence in an overtime lawsuit to pursue a class action lawsuit.
  • Financial constraints do not absolve employers from their legal obligation to provide overtime pay.

If you want to know more about overtime regulations, read our guide on West Virginia Overtime Laws.

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