Missouri Federal Court Rejects Conditional Certification in FLSA Meal Break Case

On December 10, 2025, the U.S. District Court for the Eastern District of Missouri issued a decision that provides useful guidance for healthcare employers and wage-and-hour practitioners. In Kaiser v. St. Luke’s Episcopal-Presbyterian Hospitals, Inc., the court denied conditional certification of a proposed Fair Labor Standards Act (FLSA) collective action alleging unpaid meal breaks for nurses and technicians.

Even under the FLSA’s lenient conditional certification standard, speculation and generalized theories are insufficient. Kaiser reinforces that plaintiffs must present evidence demonstrating a single, FLSA-violating compensation practice applicable to the proposed class.

Background

The plaintiff, a registered nurse, alleged that St. Luke’s violated the FLSA by failing to compensate nurses and technicians for meal periods. According to the complaint, because employees remained responsible for patient care and could be interrupted during breaks, all unpaid meal periods were compensable work time under the FLSA.

Like many healthcare employers, St. Luke’s historically used an automatic 30-minute meal break deduction but later implemented an attestation process. That process allowed employees to override the deduction and receive pay for worked meal periods.

The plaintiff sought conditional class certification under 29 U.S.C. § 216(b), asserting that nurses and technicians were similarly situated because each meal break was “subject to interruption.”

Legal Standard

At the notice stage of an FLSA collective action, the court does not evaluate the merits of the claims; however, the plaintiff must still substantially allege that proposed members were victims of a single decision, policy, or plan that violated the FLSA. While courts do not weigh credibility or resolve factual disputes at this stage, they require more than unsupported assertions or statements lacking personal knowledge.

In the Eighth Circuit, courts analyze unpaid meal break claims using the “for-the-benefit-of-the employer” standard. This standard is flexible and allows courts to consider different factors depending on the nature of the business involved. Under this framework, a meal period is compensable only if it is spent predominantly for the employer’s benefit, rather than allowing the employee to use the time effectively for their own purposes.

Denial of Conditional Certification

The court rejected the plaintiff’s theory that the mere possibility of interruption transforms an unpaid meal break into compensable work time. Relying on Eighth Circuit precedent, the court emphasized that it is neither realistic nor required under the FLSA for employers to compensate employees for meal periods during which they are relieved of duties except for being on call to respond to emergencies.

The court highlighted several evidentiary gaps that proved fatal to the plaintiff’s motion:

• No evidence of meaningful restrictions. There was no evidence that employees were required to remain on campus, stay in a specific location, or obtain permission to leave during meal breaks.
• No evidence of frequent interruptions. The record lacked evidence showing how often interruptions occurred, if at all.
• Evidence of compliant policies. The employer maintained a process allowing employees to receive compensation for meal breaks that they worked.

The plaintiff showed only the possibility of interruption, which the court held was insufficient to establish that meal periods primarily benefited the employer.

The court also distinguished a prior healthcare decision in which conditional certification was granted. In that case, the plaintiffs presented evidence that they were required to continuously provide patient care during unpaid meal breaks and were effectively unable to disengage from their duties. By contrast, the Kaiser plaintiff offered no evidence that St. Luke’s knowingly required employees to work through meal periods without compensation. The existence of the attestation process further undermined any claim of a uniform, FLSA-violating practice.

Key Takeaways for Employers

Kaiser reinforces several important principles:

• Automatic meal break deductions are not per se unlawful under the FLSA
• On-call status, standing alone, does not make a meal break compensable
• Attestation and override processes matter, both for compliance and litigation defense
• Conditional certification can be defeated at an early stage when plaintiffs fail to present evidence of actual unpaid work