KANSAS CITY — A former certified nurse’s assistant has filed a class action lawsuit alleging Bristol Care Inc. engaged in systemic wage violations affecting potentially hundreds of current and former employees.
Lauren Hayden of Calhoun, claims the company maintained policies and practices that denied minimum wages, straight time and overtime pay to its certified nurse’s assistants (CNAs) in violation of the Fair Labor Standards Act (FLSA) and Missouri wage laws, according to the Nov. 21 case filed in the U.S. District Court for the Western District of Missouri.
Hayden worked as a CNA for Bristol Care from approximately June 2024 to October 2024 at the company’s Clinton location. She asserts that Bristol Care failed to compensate her properly and other employees performing similar duties, alleging that they were “suffered or permitted” to work without receiving minimum wage, full straight time or legally required overtime premiums for all hours worked beyond 40 in a workweek.
The lawsuit states that these practices were not isolated but formed part of a continuing wage policy that violated federal and state labor standards.
Hayden brings the action on behalf of herself and all other CNAs employed by Bristol Care within the preceding three years, seeking to establish an FLSA collective action under 29 U.S.C. § 216(b).
The suit asserts that all putative collective members had substantially similar job duties, compensation structures and experiences with the alleged unpaid work.
The complaint alleges that Bristol Care exercised significant control over employees’ schedules, conditions of employment, pay methods and employment records, making the company a covered employer under the FLSA.
The filing claims that Bristol Care’s alleged failure to pay overtime, which federal law sets at one and one-half times the employee’s regular rate, was willful, entitling the plaintiffs to liquidated damages in addition to unpaid wages.
Hayden alleges that the company’s gross operating revenues exceeded $500,000 annually, making it subject to FLSA obligations.
She also alleges that Bristol Care had access to employee time and payroll records that would show the extent of unpaid hours and overtime.
Because of the alleged uniform practices, Hayden contends that notifying all affected employees via first-class mail or comparable methods is appropriate and necessary under the statute.
In addition to the federal claims, Hayden seeks certification of two Missouri Rule 23 classes covering state law claims under the Missouri Minimum Wage and Maximum Hours Laws and separate claims for unjust enrichment and quantum meruit.
Hayden alleges that Bristol Care misclassified CNAs as exempt under Missouri wage laws and failed to pay legally mandated overtime and minimum wages, similar to the FLSA violations alleged.
The complaint further claims that Bristol Care knowingly retained the benefit of unpaid labor, enriching itself at the expense of its employees.
It argues that the company acted in bad faith by failing to pay the proper rate for hours worked despite knowing or having reason to know the correct legal requirements.
The lawsuit asserts that Bristol Care’s alleged compensation practices violated both federal and Missouri wage laws continuously and systematically.
Hayden seeks restitution under an unjust enrichment theory equal to all unpaid wages plus liquidated damages. She is represented by Phillip M. Murphy II of the Law Office of Phillip M. Murphy II LLC in Kansas City.
U.S. District Court for the Western District of Missouri case number: 2:25-cv-04266
