Julian v. MetLife, Inc.

Background

Debra Julian, Tonya Gill, Stephanie McKinney, and Kimberly Harris sued MetLife, Inc. on behalf of themselves and other current and former Long-Term Disability Claim Specialists. They alleged that MetLife wrongly classified them as exempt from overtime under the Fair Labor Standards Act (FLSA) and state labor laws.

The court had conditionally certified an FLSA collective covering people employed by MetLife as Claim Specialists and Senior Claim Specialists working on long-term disability insurance claims since February 8, 2014. Notice went to 470 employees, and 78 people opted into the collective in addition to the named plaintiffs. After discovery, MetLife moved to decertify the collective and sought summary judgment on the overtime claims of eight plaintiffs. The plaintiffs opposed those motions and sought certification of a class for overtime claims under New York, Connecticut, and Illinois law.

Survey responses

MetLife had voluntarily surveyed employees about their job duties and cited some responses in support of decertification. The plaintiffs argued that the surveys were improper communications with potential class members. The court denied the motion to strike or disregard the survey responses. It found no evidence that MetLife misled, forced, manipulated, or pressured employees in connection with the survey.

FLSA collective decertification

The court granted MetLife’s motion to decertify the FLSA collective. After discovery, the court concluded that deciding whether the administrative exemption applied would require individualized evidence about each specialist’s actual duties, the way each person was supervised, and the credibility of each person’s testimony. The court found that MetLife’s general policies, manuals, job descriptions, training, and other common evidence could not resolve those individual questions for the entire collective.

The court dismissed the opt-in plaintiffs’ claims without prejudice to filing their own FLSA actions. The opinion gave as an example that Julian testified her job was gathering information for claim-discussion meetings while others made the claim determination, even though MetLife’s policies and training generally required claim specialists to exercise judgment.

Rule 23 class certification

The court denied the plaintiffs’ motion to certify a class under Federal Rule of Civil Procedure 23 for their state-law overtime claims. It reached the same conclusion as with the FLSA collective: whether a specialist was exempt depended on that person’s specific duties and whether supervision prevented that person from exercising discretion and independent judgment. The court found that these individualized inquiries prevented the proposed class from satisfying Rule 23’s requirements for commonality and predominance.

Summary judgment

The court’s overall ruling states that MetLife’s motion for summary judgment was granted in part and denied in part. Specifically, because the opt-in plaintiffs’ claims had been dismissed from the collective, the court addressed the remaining summary-judgment issues concerning Stephanie McKinney.

For McKinney’s FLSA claims, the court granted summary judgment for MetLife. The FLSA administrative exemption requires, among other things, a salary of at least $684 per week, non-manual work directly related to business operations, and a primary duty involving discretion and independent judgment on significant matters. The plaintiffs did not dispute the salary requirement.

The court found no genuine dispute of material fact about the other requirements. Claim Specialists handled long-term disability claims rather than producing or selling insurance policies. Their work included gathering and evaluating medical, employment, and other information; assessing disability and coverage; identifying discrepancies or warning signs; deciding whether to approve, deny, modify, or terminate claims; determining benefit amounts; and evaluating return-to-work issues and accommodations.

The court also found that MetLife’s manuals and expert resources did not dictate the outcome of every claim. Instead, the specialists had to choose what information and resources to use and evaluate the facts of each claim. The court held that supervisor review did not eliminate discretion because the regulations allow an employee to exercise independent judgment even when the employee’s decisions or recommendations are reviewed at a higher level. The court concluded that McKinney performed this kind of work and was exempt from FLSA overtime requirements.

For McKinney’s claims under the Connecticut Minimum Wage Act, the court denied summary judgment. Although Connecticut law also recognizes an administrative exemption, it includes an additional requirement concerning the percentage of work time spent on tasks not directly and closely related to administrative work. The court found that MetLife had not shown the absence of a genuine factual dispute about how much time McKinney spent on such tasks.

Other rulings

The court granted the plaintiffs’ motion to strike MetLife’s reply to the plaintiffs’ response to MetLife’s factual statement supporting summary judgment. The court found that the local rule did not provide for such a reply and that the plaintiffs had no opportunity to file a further response, creating a potential unfairness.

The court granted MetLife’s unopposed motion to seal certain documents containing proprietary or sensitive business information, including sample contracts, pricing structures, and business strategies. The parties’ motions for oral argument were denied as moot.

Disposition

The court denied the motion to strike or disregard MetLife employees’ survey responses; granted MetLife’s motion to decertify the FLSA collective; denied the motion to certify a Rule 23 state-law class; granted the motion to strike MetLife’s reply; granted in part and denied in part MetLife’s summary-judgment motion, specifically granting judgment on McKinney’s FLSA claims and denying it on her Connecticut claims; and granted MetLife’s motion to seal certain documents.