Secretary United States Department of Labor v. Comprehensive Healthcare Management Services LLC

── Secretary United States Department of Labor v. Comprehensive Healthcare Management Services LLC ── Court: Court of Appeals for the Third Circuit Date: June 03, 2026 Category: General PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________ No. 24-2842 _____________ SECRETARY UNITED STATES DEPARTMENT OF LABOR v. COMPREHENSIVE HEALTHCARE MANAGEMENT SERVICES LLC; MAYBROOK-C KADE OPCO, LLC; MAYBROOK-C EVERGREEN OPCO, LLC; MAYBROOK-C WHITECLIFF OPCO, LLC; MAYBROOK-C LATROBE OPCO, LLC; MAYBROOK-C OVERLOOK OPCO, LLC; MAYBROOK-C SILVER OAKS OPCO, LLC; MAYBROOK-C BRIARCLIFF OPCO, LLC; MT LEBANON OPERATIONS LLC; MURRYSVILLE OPERATIONS LLC; SOUTH HILLS OPERATIONS LLC; CHESWICK REHABILITATION AND WELLNESS CENTER, LLC; MONROEVILLE OPERATIONS LLC; NORTH STRABANE REHABILITATION AND WELLNESS CENTER, LLC; NORTH STRABANE RETIREMENT VILLAGE, LLC; CHMS GROUP LLC; SAMUEL HALPER, an individual, Appellants _____________  On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 2:18-cv-1608) District Judge: Honorable William S. Stickman IV _____________ Argued: September 10, 2025 ______________ Before: CHAGARES, Chief Judge, PORTER and ROTH, Circuit Judges (Filed: June 3, 2026) _____________ Laura Bunting-Williams Jackson Lewis 11 Stanwix Street 14th Floor Pittsburgh, PA 15222 Jeffrey A. Schwartz [ARGUED] Jackson Lewis 171 17th Street NW Suite 1200 Atlanta, GA 30363 Counsel for Appellants Dean Romhilt [ARGUED] United States Department of Labor Office of the Solicitor 200 Constitution Avenue NW 2 Room N-2716 Washington, D.C. 20210 Counsel for Appellee OPINION OF THE COURT _____________ CHAGARES, Chief Judge. Comprehensive Healthcare Management Services LLC (“Comprehensive”) owned and operated a number of healthcare facilities across Pennsylvania. Soon after Comprehensive acquired the facilities, the United States Department of Labor began investigating the facilities for wage and hour violations. As a result of its investigation, the Secretary of the Department of Labor (the “Secretary”) filed suit against Comprehensive 1 on behalf of nearly 6,000 employees, alleging that Comprehensive violated several provisions of the Fair Labor Standards Act (the “FLSA”). The District Court held a bench trial and ultimately found in favor of the Secretary, awarding $35,804,438.20 in damages. Included in that sum was an award for “overtime” gap time — that is, compensation for non-overtime hours worked in a pay period when an employee has worked overtime hours. While we have held that claims for “pure” gap 1 In full, defendant-appellants include sixteen entities, as well as Samuel Harper, the chief executive officer of the facilities. For ease of reference, the Court will refer to defendant- appellants collectively as “Comprehensive.” 3 time — compensation for non-overtime hours worked during pay periods when an employee has not worked overtime hours — are not cognizable under the FLSA, Davis v. Abington Memorial Hospital, 765 F.3d 236, 244 (3d Cir. 2014), we have not had occasion to consider whether claims for overtime gap time are viable. Today, for the reasons set forth below, we hold that they are not and will thus reverse the District Court’s order on that ground. We also address Comprehensive’s additional claims of error. Namely, Comprehensive claims that the District Court impermissibly held the Secretary to a lower burden of proof on certain claims, committed clear error in several of its factual findings, and improperly concluded that certain Comprehensive employees were nonexempt under the FLSA. As set forth below, we are not persuaded by Comprehensive’s first two argument