Secretary United States Department of Labor v. Comprehensive Healthcare Management Services LLC
Split Score
What is a Split Score?
This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Reversed in Part
The Third Circuit held that the Fair Labor Standards Act does not provide a cause of action for employees seeking unpaid straight-time wages worked during weeks in which they also worked overtime ("overtime gap time"). Accordingly, it reversed the district court’s inclusion of those damages. The panel otherwise affirmed most liability findings but vacated and remanded the exemption analysis for certain employees.
Circuit Split Identified
Legal Issue
Whether the Fair Labor Standards Act (FLSA) permits employees to recover damages for "overtime gap time"—i.e., unpaid straight-time hours worked during weeks in which the employee also worked more than forty hours.
Circuit Positions
FLSA does NOT recognize overtime gap time claims; recovery is limited to minimum wage and overtime premiums.
FLSA DOES recognize overtime gap time claims based on DOL interpretive guidance and the statute's remedial purpose.
Conflict Summary
The Second and Third Circuits hold that the FLSA provides remedies only for minimum-wage and overtime violations and therefore does not allow recovery for unpaid straight-time hours in an overtime week (overtime gap time). The Fourth Circuit defers to Department of Labor guidance and permits such claims, reasoning that failure to pay straight time for all forty hours undermines correct overtime calculations.