Kpaduwa v. UnitedHealth Group

Background

The plaintiffs alleged that UnitedHealth Group, Optum, Inc., and the Advisory Board Company violated the Fair Labor Standards Act, Minnesota’s overtime wage law, and Maryland wage-and-hour and wage-payment laws. The plaintiffs worked as consultants providing recordkeeping support and training to the defendants’ clients in Maine, Maryland, and Washington, D.C., between 2016 and 2019.

The plaintiffs had previously opted into an earlier putative class action involving the same alleged conduct. After discovery, depositions, and briefing, the court in that earlier case decertified the class and granted summary judgment in part for the defendants. It dismissed the federal wage claim as untimely because the named plaintiff had not shown that the defendants’ alleged violations were willful. The court later dismissed all opt-in plaintiffs, including the plaintiffs here, from that action without prejudice.

The plaintiffs then filed this case on September 7, 2021, asserting the same claims and alleged misconduct. The defendants moved to dismiss the Fair Labor Standards Act claim based on collateral estoppel, a rule that prevents a party from relitigating an issue of fact or law that was fully decided in an earlier case.

Court’s Analysis

The Fair Labor Standards Act generally provides a two-year limitations period for non-willful violations and a three-year period for willful violations. Because the plaintiffs’ allegations largely involved conduct from 2016 and 2017, the court said most of those allegations were untimely even if the three-year period applied. Jimmy Ajuwa alleged that he worked for the defendants from July 2018 through September 2019, so the court found that his claim might include conduct within the two-year period.

The court concluded that collateral estoppel applied to the willfulness issue because: (1) the issue had been fully litigated in the earlier action; (2) the earlier court had entered a valid final judgment on it through summary judgment; (3) these plaintiffs had been parties to the earlier case as opt-in plaintiffs; and (4) the willfulness determination was essential to deciding whether the federal claims were timely. The court rejected the argument that decertification freed the former opt-in plaintiffs to relitigate issues already decided on summary judgment.

Disposition

Judge David S. Doty granted the motion to dismiss in part. The order states that, to the extent Count I was based on conduct occurring before September 7, 2019, the plaintiffs’ Fair Labor Standards Act claim was dismissed with prejudice. The court did not dismiss Jimmy Ajuwa’s claim at that time because his precise employment dates were not yet known and his allegations could support a timely claim without relying on willfulness. The opinion does not state a separate disposition of the state-law claims.