Florida Court Decertifies Wage Lawsuit Against Hospitals

Plaintiffs' circumstances too individualized to maintain FLSA collective action, judge rules.

Published on Feb. 4, 2026

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A Florida federal district court granted NCH Healthcare System, Inc. and Naples Community Hospital, Inc.'s motion to decertify a collective action under the Fair Labor Standards Act brought by a nurse who alleged that the hospital's $5,000 program fee for nurses who left before completing a two-year fellowship constituted an illegal kickback that denied minimum wage. The judge found that the four plaintiffs' circumstances were too individualized regarding how the fee was collected to maintain certification.

Why it matters

This case highlights the challenges plaintiffs can face in maintaining collective actions under the FLSA, particularly when there are individualized factors at play regarding the alleged labor law violations. The ruling underscores the high bar courts set for collective certification in wage and hour lawsuits.

The details

The lawsuit was brought by a nurse who claimed the $5,000 program fee imposed by the hospitals on nurses who left before completing a two-year fellowship constituted an illegal kickback that denied them minimum wage. However, the court found that the four plaintiffs' circumstances regarding how the fee was collected were too individualized to maintain the collective action. For example, some plaintiffs had the fee deducted from their final paychecks, while others set up payment plans.

  • The lawsuit was filed in 2024.
  • The court granted the motion to decertify the collective action in February 2026.

The players

NCH Healthcare System, Inc.

A healthcare system operating hospitals in Naples, Florida.

Naples Community Hospital, Inc.

A hospital operated by NCH Healthcare System in Naples, Florida.

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The takeaway

This case underscores the high bar courts set for collective certification in FLSA lawsuits, particularly when there are individualized factors at play regarding the alleged labor law violations. Plaintiffs must demonstrate that their circumstances are sufficiently similar to maintain a collective action.