E.D. Mo. Judge Sarah E. Pitlyk denied MHM Health Professionals’ motion for partial summary judgment in a collective action alleging the healthcare staffing company underpaid employees following a 2021 Kronos ransomware outage.
The dispute centers on whether MHM paid overtime wages “as soon as practicable” after its timekeeping software was disabled. During the outage, MHM used a manual spreadsheet to track hours but chose not to calculate pay from that data. Instead, the company estimated wages by duplicating prior pay periods and promised to reconcile differences later.
Plaintiff Penny Lewis argued that MHM had all the necessary information to calculate wages accurately during the outage but elected not to use it. She pointed to internal communications and deposition testimony showing that employees were required to track their hours in a “Centurion Hours Tracker” spreadsheet.
MHM countered that it was impossible to manually calculate the complex payroll rules, including shift differentials and overtime formulas, without its automated system. The company argued it acted diligently by running an out-of-cycle payroll for severely underpaid employees and communicating transparently about the payment delays.
Judge Pitlyk denied summary judgment, ruling that a reasonable juror could find MHM did not pay wages as soon as practicable. The court noted that credibility determinations and the plausibility of inferences regarding MHM’s preparedness are jury functions, not appropriate for summary judgment.
The denial extends to Lewis’s claims under the Arizona Wage Act and state common law unjust enrichment. The court held that factual disputes regarding whether MHM’s conduct constituted a “reasonable good faith dispute” over wages due precluded judgment as a matter of law.