Li v. Greatcare, Inc.

Background

Fourteen home-care aides sued Great Care, Inc., CenterLight Healthcare, Inc., and unnamed managed long-term care plans. They asserted claims under the Fair Labor Standards Act and the New York Labor Law. The plaintiffs alleged that they worked repeated 24-hour shifts but were paid for no more than 13 hours per shift and were not paid required overtime or other compensation.

Hei Li was the only plaintiff asserting claims against CenterLight. She alleged that GreatCare and CenterLight jointly employed her from approximately June 2017 through December 2021 to provide live-in care to an elderly Medicaid recipient. She alleged that she slept no more than two or three hours per night, slept on a couch, and was not paid for all of her work. Her claims against CenterLight were under New York law; she conceded that she was not asserting Fair Labor Standards Act claims against CenterLight.

CenterLight’s Motions

CenterLight moved under Rule 12(b)(1), which concerns subject-matter jurisdiction, arguing that the federal court could not hear Li’s New York-law claims. It also moved under Rule 12(b)(6), which concerns whether a complaint states a legally sufficient claim, arguing that any Fair Labor Standards Act claims by Li were untimely. Alternatively, CenterLight asked the court to sever Li’s claims into a separate action under Rule 21.

Supplemental Jurisdiction

The court concluded that it had supplemental jurisdiction over Li’s claims. Supplemental jurisdiction allows a federal court that already has jurisdiction over federal claims to hear related state-law claims that form part of the same constitutional case or controversy.

The court found that Li’s New York-law claims and the other plaintiffs’ federal claims arose from a common set of facts. The claims involved alleged wage violations affecting home-care aides who worked 24-hour shifts, GreatCare’s alleged role as a joint employer, the managed-care plans’ alleged authorization of live-in services, and allegedly common reimbursement and compensation policies. The court therefore held that Li’s claims were sufficiently related to the other plaintiffs’ Fair Labor Standards Act claims.

The court also declined to reject supplemental jurisdiction. It found that the claims did not present unusually complex state-law issues, that Li’s claims did not substantially outweigh the federal claims, that the federal claims had not been dismissed, and that there were no exceptional circumstances requiring the court to decline jurisdiction.

The court noted that CenterLight disputed whether it employed the aides and asserted that it merely managed funds and acted as a liaison between the state and home-care agencies. The court stated that the existence and nature of the employment relationships involved factual issues that could not be resolved at the motion-to-dismiss stage.

Timeliness Argument

CenterLight argued that Fair Labor Standards Act claims would be time-barred because Li’s work ended in December 2021 and the lawsuit was filed on October 1, 2024. Li responded that she asserted only New York Labor Law claims against CenterLight. CenterLight did not dispute that those state-law claims were timely. The court therefore denied the motion to dismiss the claims as time-barred.

Severance

The court also denied CenterLight’s request to sever Li’s claims. Applying factors concerning overlapping transactions, common legal or factual questions, efficiency, prejudice, and the need for different evidence, the court found that none favored severance. It concluded that Li’s claims were sufficiently related to the other plaintiffs’ claims that separating them would be inefficient.

Disposition

The court denied CenterLight’s motion to dismiss and, alternatively, to sever in its entirety. The case remained referred to Magistrate Judge Katharine H. Parker for general pretrial management. This order did not decide whether CenterLight was liable for any wage-law violation.