Cook v. Amedisys Inc.
Allegations that a plaintiff was wrongly classified as exempt and was not compensated, when the plaintiff worked more than 40 hours per week, may be sufficient to state a claim pursuant to the Fair Labor Standards Act. Allegedly, the defendant employer, Amedisys Inc., hired a registered nurse, Julie Cook, and failed to pay her overtime and time-and-one-half pay, when she worked more than 40 hours per week. Cook and other plaintiffs filed a putative class action, on behalf of themselves and similarly situated workers who worked as home health clinicians, alleging that the defendant employer violated the Fair Labor Standards Act. Amedisys, which has headquarters located in Louisiana, moved to transfer the suit to Louisiana, pursuant to 28 United States Code §1404(a). A presumption exists in favor of the plaintiffs' choice of forum. The court considered whether a preponderance of the evidence favored the Louisiana forum. The name plaintiffs' allegations concerned conduct that took place in Connecticut and Pennsylvania. Corporate policies were adopted in Louisiana. The court found that the locus of operative facts was neutral with respect to where conduct that led to the plaintiffs' claims took place. Although many pertinent documents are located in Louisiana, as a result of modern technology their current location does not require transfer of the suit to Louisiana. Travel to Louisiana would be inconvenient for the name plaintiffs, and transfer to Louisiana is not required for the convenience of witnesses and parties. The Connecticut court is experienced with the Fair Labor Standards Act, and transfer to Louisiana is not required as a result of lack of familiarity with governing law. Transfer may delay the resolution of the plaintiffs' claims. Trial efficiency does not require transfer to Louisiana. The balance of factors did not require transfer to Louisiana, and the court denied Amedisys' motion to transfer. The court also denied Amedisys' argument that the plaintiffs' complaint failed to state a claim and was ambiguous. The plaintiffs' complaint adequately alleged that the plaintiffs were wrongly classified as exempt and were not compensated and paid overtime, when they worked more than 40 hours per week.