A former employee has launched a collective action lawsuit against her previous employer, alleging systemic wage violations. Shaunda Ephraim filed the complaint in the United States District Court for the Northern District of Illinois on July 3, 2024, targeting American Heritage Protective Services, Inc.
Ephraim claims that American Heritage Protective Services engaged in unlawful practices by failing to pay non-exempt employees for all hours worked, including overtime compensation. The lawsuit asserts that these actions are in direct violation of the Fair Labor Standards Act (FLSA), which mandates overtime pay at one and one-half times the regular rate for hours worked beyond 40 in a workweek. According to the complaint, Ephraim and other similarly situated employees were required to perform unpaid work before and after their shifts, such as conducting "pass down" activities where security officers exchanged information about security issues from previous shifts.
The plaintiff's allegations are detailed and comprehensive. She was employed by American Heritage Protective Services from September 27, 2023, to May 23, 2024, initially as a security supervisor and later as an associate security officer in Michigan. During this period, she claims she was scheduled to work at least 40 hours per week but often exceeded this amount due to additional tasks performed outside her scheduled hours. Ephraim argues that these extra duties were integral to her role and should have been compensated accordingly. She estimates spending an additional 15 minutes or more before and after each shift on these tasks.
Ephraim's complaint highlights that American Heritage Protective Services' failure to compensate for this time not only violated FLSA regulations but also demonstrated a willful disregard for the law. The company allegedly did not make any good faith effort to comply with FLSA requirements and failed to maintain accurate records of the unpaid work performed by its employees.
In seeking justice, Ephraim is requesting several forms of relief from the court. These include actual damages for unpaid wages, statutory liquidated damages, pre- and post-judgment interest at the statutory rate, attorneys’ fees, costs, disbursements, and any further relief deemed just and proper by the court. Additionally, she seeks an order permitting this litigation to proceed as a collective action under FLSA guidelines and prompt notice to all potential class members about their right to opt into the lawsuit.
Representing Ephraim are attorneys Matthew S. Grimsley and Anthony J. Lazzaro from The Lazzaro Law Firm LLC based in Moreland Hills, Ohio. The case has been assigned Case No.: 1:24-cv-05620 in front of an unnamed judge.