Judge Denies Motion to Dismiss in Wage-and-Hour Class Action, Excluding Extrinsic Evidence

CHICAGO (LN) — U.S. District Judge Jeremy C. Daniel denied Helia Healthcare Services, LLC's motion to dismiss a putative wage-and-hour class action, ruling that the employer's attached pay stubs and emails were extrinsic evidence that could not be considered without converting the motion to summary judgment.

The order, issued March 13, 2026, in Amanda High v. Helia Healthcare Services, LLC (No. 25 CV 13716), allows the case to proceed on allegations that Helia automatically deducted 30 minutes from hourly employees' recorded time without providing breaks or pay.

Plaintiff Amanda High, who worked for Helia from October 2022 to March 2025, alleged the company failed to pay proper overtime rates and excluded regular pay from bonus calculations.

Helia moved to dismiss under Federal Rules of Civil Procedure 12(b)(6), 12(b)(7), and 12(c), asserting it never employed High, did not deduct time from paychecks, and that she failed to name a necessary party.

In its two-page motion, Helia attached a purported pay stub, an email between counsel, and a memo on its timekeeping policy.

Daniel ruled the documents were not mentioned in High's complaint and thus fell outside the exception for documents central to the claims.

"Generally, a court may not consider extrinsic evidence attached to a motion to dismiss without converting the motion into one for summary judgment," Daniel wrote, citing Brownmark Films, LLC v. Comedy Partners.

The judge exercised his discretion to deny Helia's request to convert the motion, noting that the veracity of the plaintiff's allegations is not at issue stage.

Daniel also rejected Helia's argument that High failed to join a necessary party, stating the employer made no effort to argue the requirements under Rule 19 were satisfied.

"The allegations discussed above provide sufficient facts to state a plausible claim to relief, and Helia has not contested the sufficiency of High's allegations," Daniel wrote.

The court ordered Helia to answer the complaint by April 3, 2026, and set a scheduling conference for April 23, 2026.