{"id":2847,"date":"2026-03-30T15:13:59","date_gmt":"2026-03-30T19:13:59","guid":{"rendered":"https:\/\/blogs.duanemorris.com\/classactiondefense\/?p=2847"},"modified":"2026-03-30T15:14:00","modified_gmt":"2026-03-30T19:14:00","slug":"overtime-case-loses-pulse-new-york-federal-court-finds-medical-school-researchers-are-learned-professionals-exempt-from-flsa-and-denies-bid-for-collective-action-certification","status":"publish","type":"post","link":"https:\/\/blogs.duanemorris.com\/classactiondefense\/2026\/03\/30\/overtime-case-loses-pulse-new-york-federal-court-finds-medical-school-researchers-are-learned-professionals-exempt-from-flsa-and-denies-bid-for-collective-action-certification\/","title":{"rendered":"Overtime Case Loses Pulse: New York Federal Court Finds Medical School Researchers Are Learned Professionals Exempt From FLSA And Denies Bid For Collective Action Certification"},"content":{"rendered":"
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By Gerald L. Maatman, Jr., Elizabeth Underwood, and Olga A. Romadin<\/p>\n\n\n\n

Duane Morris Takeaways:<\/em><\/strong> On March 26, 2026, Judge Paul Engelmayer of the U.S. District Court for the Southern District of New York issued an order denying<\/a> certification of a Fair Labor Standards Act (\u201cFLSA\u201d) collective action brought by a study coordinator alleging that his employer, a medical school, misclassified him and a group of similarly-situated individuals in Castillo, et al. v. Albert Einstein College of Medicine, Inc. et al.<\/em>, No. 24 Civ. 00984,<\/em> 2026 WL 834712 (S.D.N.Y. Mar. 26, 2026). Following discovery, the Court found that a higher standard for the first step of the conditional certification process was warranted, and on review of evidence submitted by the defendants as well as the plaintiff, it declined to certify the collective action, concluding that the differences in coordinators\u2019 duties precluded a collective action.<\/em><\/p>\n\n\n\n

Case Background<\/strong><\/p>\n\n\n\n

Plaintiff, a researcher in the Cognitive Neurophysiology Laboratory of the Albert Einstein College of Medicine, a medical school based in New York, brought a collective action against the College and three related entities, including a teaching college and the schools\u2019 parent corporations, alleging that they had misclassified study and research coordinators as \u201clearned professionals\u201d exempt from overtime under the FLSA. Id.<\/em> at *3.<\/p>\n\n\n\n

The College filed a motion to dismiss Castillo\u2019s amended complaint in July 2024, arguing that it was not an \u201cemployer\u201d under the FLSA and NYLL, but the Court found this unavailing and denied the motion, and the parties proceeded to discovery. Id.<\/em> at *1. Castillo then moved for conditional certification under the FLSA, seeking to encompass a collective of current and former employees working as research and study coordinators for the College of Medicine and its related entities who he alleged were not compensated for overtime work. Id<\/em>. Castillo also sought to toll the FLSA statute of limitations period and asked the Court to authorize notice to individuals employed by the defendants as far back as three years. Id.<\/em><\/p>\n\n\n\n

 The District Court\u2019s Decision<\/strong><\/p>\n\n\n\n

The Court found that, in light of the substantial discovery between the parties, the plaintiff faced a higher threshold requirement of making a \u201cmodest plus\u201d factual showing in step one of the Second Circuit\u2019s two-step process to certify a collective action under the FLSA, which it ruled Castillo had failed to meet because evidence submitted by both parties was not convincing that a collective of similarly-situated individuals existed. Id.<\/em> at *5.<\/p>\n\n\n\n

In its analysis, the Court noted that classifying a category of employees as learned professionals exempt under the FLSA is not, on its own, enough for a finding of a \u201ccommon policy, plan, or practice\u201d to find them to be \u201csimilarly situated.\u201d Id.<\/em> at 6. Plaintiffs have to show a uniform misclassification by identifying individuals with similar duties and responsibilities, and Castillo had failed to do so here because his reliance on two declarations and six job descriptions lacked the weight and detail necessary to account for the work of hundreds of individuals in dozens of departments and programs across the institutions. Id. <\/em>at *7-8.<\/p>\n\n\n\n

The Court was further swayed by the defendants\u2019 evidence of substantial job descriptions showing a variety of duties and responsibilities both demonstrating variation and fitting into the learned professional exemption.  Id.<\/em> at *8-9. Defendants produced 49 job descriptions demonstrating that coordinators\u2019 duties ran the gamut\u2014while some were primarily tasked with data collection, others were responsible for developing clinical studies, making medical recommendations, or engaging with patients\u2014and had \u201cdiffering levels of intellectual rigor\u201d and educational requirements. Id.<\/em> <\/p>\n\n\n\n

Finally, the Court found that Castillo\u2019s reliance on the deposition testimony of the College\u2019s vice president of human resources actually bolstered the defendants\u2019 position that the duties and responsibilities of coordinators vary widely from one position to the next, undermining his argument that they are similarly situated and thus eligible for conditional certification. Id.<\/em> at *10-11.<\/p>\n\n\n\n

 Implications For Employers<\/strong><\/p>\n\n\n\n

This decision offers several practical takeaways for employers in fields where workers may fall under an FLSA exemption.  Employers are well-served by maintaining and cataloging detailed job descriptions that accurately reflect the duties and educational requirements of each position.<\/p>\n\n\n\n

The Court\u2019s decision also highlights the strategic value of the \u201cmodest plus\u201d standard for defendants facing FLSA conditional certification motions.  Where pre-certification discovery has already taken place, defendants in many circuits may involve this heightened standard and submit their own evidence to demonstrate that putative class members are not similarly situated with respect to their job duties and requirements.<\/p>\n","protected":false},"excerpt":{"rendered":"

By Gerald L. Maatman, Jr., Elizabeth Underwood, and Olga A. Romadin Duane Morris Takeaways: On March 26, 2026, Judge Paul Engelmayer of the U.S. District Court for the Southern District of New York issued an order denying certification of a Fair Labor Standards Act (\u201cFLSA\u201d) collective action brought by a study coordinator alleging that his … <\/p>\n

Continue reading “Overtime Case Loses Pulse: New York Federal Court Finds Medical School Researchers Are Learned Professionals Exempt From FLSA And Denies Bid For Collective Action Certification”<\/span><\/a><\/p>\n","protected":false},"author":575,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[42],"tags":[],"ppma_author":[7,149,156],"class_list":["post-2847","post","type-post","status-publish","format-standard","hentry","category-wage-hour-litigation"],"authors":[{"term_id":7,"user_id":575,"is_guest":0,"slug":"gmaatman","display_name":"Gerald L. Maatman, Jr.","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2022\/09\/maatmangerald-100x100.jpg","author_category":"","last_name":"Maatman Jr.","first_name":"Gerald L.","job_title":"","user_url":"https:\/\/www.duanemorris.com\/attorneys\/geraldmaatman.html","description":"Read Gerald's bio.<\/a>"},{"term_id":149,"user_id":744,"is_guest":0,"slug":"eunderwood","display_name":"Elizabeth Underwood","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/10\/underwoodelizabeth-100x100.jpg","author_category":"","last_name":"Underwood","first_name":"Elizabeth","job_title":"","user_url":"https:\/\/www.duanemorris.com\/attorneys\/elizabethunderwood.html","description":"Read Elizabeth's bio."},{"term_id":156,"user_id":756,"is_guest":0,"slug":"oromadin","display_name":"Olga Romadin","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2026\/02\/romadinolga-100x100.jpg","author_category":"","last_name":"Romadin","first_name":"Olga","job_title":"","user_url":"https:\/\/www.duanemorris.com\/attorneys\/olgaromadin.html","description":"Read Olga's bio.<\/a>"}],"_links":{"self":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts\/2847","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/users\/575"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/comments?post=2847"}],"version-history":[{"count":0,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts\/2847\/revisions"}],"wp:attachment":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/media?parent=2847"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/categories?post=2847"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/tags?post=2847"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/ppma_author?post=2847"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}