Overtime, FMLA Claims Survive Summary Judgment Against Upstate Hospital

In Albertin v. Nathan Littauer Hospital and Nursing Home, 2021 WL 1742280 (N.D.N.Y. May 4, 2021), the court, inter alia, denied defendants’ motion for summary judgment on plaintiff’s claims of overtime violations under the Fair Labor Standards Act (FLSA) and interference and retaliation under the Family and Medical Leave Act (FMLA).

In this post, I will not delve into the court’s specific reasoning regarding the assessment of the merits of these claims. Rather, I will note the Judge’s thoughtful and interesting analogy, at the conclusion of the opinion, regarding interpersonal workplace dynamics:

The word “chemistry” gets a lot of use as a shorthand for how well two people get along. Unlike most metaphors, which thrive on reduction, chemistry as a metaphor for personal interactions tends to work on more levels as more people are added. Take the workplace. The perfect balance of personalities in the perfect roles produces an efficient, relaxed environment, maximizing production without straining the employees, much like a perfectly balanced chemical reaction produces the intended outcome without wasting resources.

However, just like using the wrong proportions or chemicals could result in any number of outcomes ranging from nothing to explosion, the wrong people in a workplace can ruin productivity or lead to climactic conflict. This case, whatever its merits ultimately turn out to be, is a classic example of a bad reaction between two people that soured the entire complexion of NLH’s human resources workforce.

That bad reaction has run its course, and all this time later there remain a number of unanswered questions concerning Albertin’s employment at NLH. None of those questions are for the Court to decide. Trial alone can provide an answer.

This, of course, does not mean that “bad chemistry” between/among employees at work will necessarily entitle one to a jury trial on employment discrimination claims.

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