The company maintains what it calls a “registry” of its nurses, and it connects those nurses with work opportunities at its client healthcare facilities.
A company that does business as Steadfast Medical Staffing was liable as an employer for the unpaid overtime claims—totaling more than $9.3 million—of approximately 1,100 nurses improperly treated as “independent contractors” under the FLSA, the Fourth Circuit affirmed. The appeals court rejected the company’s contentions that the district court misallocated the burden of proof on the worker classification issue, that the district court’s analysis of the “control factor” conflicts with Fourth Circuit worker classification precedent, that each of the other “economic realities” factors favor the company, and that the company proved its good faith affirmative defense against an award of liquidated damages. Judge Richardson dissented (Chavez-DeRemer v. Medical Staffing of America, LLC, Nos. 23-2176 and 23-2284 (4th Cir. July 17, 2025)).
Medical staffing company. Steadfast, according to the court, is a Virginia medical staffing services business that was founded in Norfolk in 2015. It supplies licensed nurses to multiple healthcare facilities located in Virginia and surrounding states, and in order to do so, it maintains what it calls a “registry” of its nurses and connects those nurses with work opportunities at its client healthcare facilities.
Application to become “employee.” To qualify for inclusion in registry, a nurse...
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