IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

COMPLAINT

NOW COMES Plaintiff, SHAWNTIA SMITH, on behalf of herself and all other 

Plaintiffs similarly situated, by and through her attorneys, JOHN W. BILLHORN AND SAMUEL 

D. ENGELSON, and for her Complaint against Defendants, DIALYSIS CARE CENTER 

OLYMPIA FIELDS LLC AND DIALYSIS CARE CENTER HOLDINGS LLC AND STEPHANIE 

SHUMATE (each a “Defendant”, collectively the “Defendants”) states as follows:

I. NATURE OF ACTION

1. This action is brought under the Fair Labor Standards Act, 29 U.S.C. §201, et seq., 

the Illinois Minimum Wage Law, 820 ILCS §105/1 et seq. and the Illinois Wage Payment and 

Collection Act (“IWPCA”), 820 ILCS 115/1, et seq. Plaintiff also asserts a claim under the 

retaliation provisions of the Fair Labor Standards Act, 29 U.S.C. §201, et seq.

II. JURISDICTION AND VENUE

2. Jurisdiction arises under the provisions of the Fair Labor Standards Act, 29 

U.S.C. §§ 206-207, and for the supplemental Illinois statutory claims, pursuant to 28 U.S.C. 

SHAWNTIA SMITH, on behalf of herself, 

and all other plaintiffs similarly situated,

known and unknown,

Plaintiff,

v.

DIALYSIS CARE CENTER OLYMPIA 

FIELDS LLC, A DELAWARE LIMITED 

LIABILITY COMPANY, DIALYSIS CARE 

CENTER HOLDINGS LLC, A DELAWARE 

LIMITED LIABILITY COMPANY AND 

STEPHANIE SHUMATE, INDIVIDUALLY

Defendants.

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No. 20-cvDistrict Judge

Magistrate Judge 

JURY DEMAND

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§1367. Venue lies in the Northern District of Illinois in that during all times relevant to the 

employment relationship, Plaintiff performed work in this district and is a resident of this 

district and Defendants are or were engaged in business in this district.

III. THE PARTIES

3. Defendant, DIALYSIS CARE CENTER OLYMPIA FIELDS LLC (hereinafter 

“DCCOF”) provides dialysis services and treatments for patients. Defendant DCCOF has its 

facility at 15786 S. Bell Road, Homer Glen, Illinois. DCCOF maintains its corporate 

headquarters at 16192 Coastal Highway, Lewes, Delaware. Defendant DCCOF is an 

“enterprise” engaged in commerce or in the production of goods for commerce within the 

meaning of 29 U.S.C. §203. During all relevant times, Defendant was acting directly or 

indirectly in the interest of the employer in relation to the employee Plaintiff and therefore, 

as defined under both the federal and state statutes relied upon, is an “employer.”

4. Defendant, DIALYSIS CARE CENTER HOLDINGS LLC (hereinafter “DCCH”) is 

a related or affiliated corporate entity of DCCOF and, among potentially other business 

interests, provides the same or similar dialysis treatment services as DCCOF. Defendant

DCCH maintains its corporate headquarters at 16192 Coastal Highway, Lewes, Delaware. 

Defendant DCCH is an “enterprise” engaged in commerce or in the production of goods for 

commerce within the meaning of 29 U.S.C. §203. During all relevant times, Defendant was 

acting directly or indirectly in the interest of the employer in relation to the employee Plaintiff 

and therefore, as defined under both the federal and state statutes relied upon, is an 

“employer.”

5. Defendant STEPHANIE SHUMATE is the regional manager for DCCH whose 

territory, which comprised of multiple Illinois facilities, included DCCOH. In her capacity as 

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a regional manager of DCCH, Shumate was vested with the authority to implement and carry 

out the wage and hour practices of DCCH and DCCOH. Shumate supervised numerous 

facilities, including DCCOH, and, as described in more detail below, personally involved 

herself with the hours and pay of DCCH employees, including Plaintiff. The named Plaintiff 

was directed to, and did, communicate all employment issues, including the wage and hour 

violations asserted herein, to Shumate and Shumate in turn responded to those

communications with the authority described above. Thus, at all times relevant hereto,

Shumate was acting directly or indirectly in the interest of the employer in relation to the 

employee Plaintiff and therefore as defined under both the federal and state statutes relied 

upon, is an “employer”.

6. Plaintiff, SHAWNTIA SMITH (hereinafter referred to as “the named Plaintiff”),

was employed as an hourly “dialysis technician” who performed duties associated with 

providing and assisting patients with dialysis treatment. The named Plaintiff worked hours in 

excess of forty (40) in a workweek, including work that was not recorded or accounted for by 

Defendants’ time keeping system (hereinafter referenced as “work off the clock”) and, in work 

weeks in which she worked in excess of forty hours including the work off the clock, was 

denied time and one-half compensation for all such hours. Additionally, Plaintiff alleges that 

Defendants’ management employees, including Shumate, altered and reduced the electronic 

timesheets of Plaintiff and members of the Plaintiff Class, which resulted in non-payment of

earned wages and overtime wages, in order to avoid the obligations imposed by the federal 

and state laws referenced herein.

7. All other unnamed Plaintiffs, known and unknown (hereinafter referred to as 

“members of the Plaintiff Class” or “similarly situated Plaintiffs”), are past or present 

employees who work or worked for Defendants and were paid hourly wages and also 

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performed work off the clock as described above and also were denied pay at time and onehalf compensation. As employees performing duties for an enterprise engaged in commerce, 

the named Plaintiff and all members of the Plaintiff Class were also engaged in commerce as 

defined by the FLSA. 

IV. STATUTORY VIOLATIONS

Collective Action Under The Fair Labor Standards Act

8. Pursuant to the Fair Labor Standards Act (FLSA), 29 U.S.C. §216(b), Count I 

of this action is brought by Plaintiff as an opt-in representative or collective action, on behalf 

of herself and other Plaintiffs similarly situated who have been damaged by Defendants’

failure to comply with 29 U.S.C. §201 et seq. and §251 et seq. Count II alleges a willful violation 

of the FLSA and seeks an additional third year of limitations. Count III seeks liquidated 

damages under the Fair Labor Standards Act, §260. Count VI alleges retaliation against 

Plaintiff by Defendants in violation of the FLSA and seeks lost wages and punitive damages.

Illinois Minimum Wage Law

9. Pursuant to the Illinois Minimum Wage Law (IMWL), 820 ILCS §105/1 et 

seq., Count IV of this action is brought by Plaintiff to recover unpaid back wages earned on 

or before the date three (3) years prior to the filing of this action. Every Plaintiff who joins this 

case in the future shall specifically adopt and assert the claims made under this Count IV. The 

claims asserted by Plaintiffs herein under the IMWL are proper for certification under Federal 

Rule of Civil Procedure 23.

Illinois Wage Payment and Collection Act

10. Pursuant to the Illinois Wage Payment and Collection Act, 820 ILCS §115/1 

et seq., Count V of this action is brought by Plaintiff to recover compensation and wages that 

were earned but not paid by Defendants, by which Plaintiff and Defendants had agreed would 

be paid, on or before ten (10) years prior to the date of filing of this action. Each and every 

Plaintiff who joins this case in the future shall specifically adopt and assert the claims made 

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under this Count VI. The claims asserted by Plaintiffs herein under the IWPCA are proper 

for certification under Federal Rule of Civil Procedure 23.

V. FACTUAL ALLEGATIONS RELEVANT TO ALL COUNTS 

11. Plaintiff, at all times pertinent to the cause of action, was employed by 

Defendants, said employment being integral and indispensable to Defendants’ business.

12. Plaintiff was employed by Defendants as a dialysis technician from June 2019 

to February 7, 2020.

13. Plaintiff typically at least 5 days per week and approximately 40-50 hours per 

week. Plaintiff’s weekly schedule and the start and end times of each shift varied.

14. Plaintiff’s job duties included performing tasks associated with administering 

dialysis treatment to patients, such as:

a) ensuring treatment was administered properly;

b) monitoring patient’s vital signs;

c) conduct a treatment assessment approximately every 30 minutes;

d) administer and conduct treatment consistent with doctor instruction; 

and

e) other general patient care.

15. Defendants extended a written offer of employment to Plaintiff through an offer 

letter. Defendants agreed to pay Plaintiff an hourly rate of pay of approximately $22.50 for 

all work she performed for Defendants. Plaintiff accepted Defendants’ offer.

16. During the course of her employment, Plaintiff was required to clock in and 

out for all shifts using the Paylocity platform used by Defendants. Plaintiff always clocked in 

and out of her shifts in accordance with Defendants’ policies.

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17. During one two-week pay period in November 2020, Plaintiff had worked 

approximately 93 total hours, for which she expected to be paid approximately 80 hours of 

regular time and 13 hours of overtime. On the Sunday prior to Wednesday payday, Plaintiff 

checked her timesheet on Paylocity and saw the correct hours reflected. On approximately 

Tuesday night, right before Plaintiff was to be paid via direct deposit on Wednesday, Plaintiff 

observed, through no action of her own, that her timesheet reflected approximately only 10 

hours of overtime instead of 13.

18. Plaintiff immediately raised the issue with Defendant Stephanie Shumate, who 

Plaintiff understood to be in a position comparable to a regional manager that oversaw many 

of the Chicago-area facilities, via text message. Defendant Shumate responded to Plaintiff’s 

complaint regarding the altered timesheet by asking Plaintiff who had authorized her 

overtime.

19. Defendant Shumate informed Plaintiff via reply text that the overtime hours 

that had been removed were not authorized by Shumate or the acting facility manager and 

would not be paid.

20. In approximately late November, following Plaintiff’s complaint of altered 

timesheets to Defendant Shumate, Plaintiff participated in a conference call that included 

Plaintiff and Shumate, as well as the supervising nurse (Stephanie) and the Vice President of 

Clinical Operations (Monique). During this call, Plaintiff again raised her concern regarding 

the altered timesheet. In response, Defendant Shumate confirmed that she had reduced 

Plaintiff’s hours in Paylocity by way of Shumate’s admin privileges within the platform. 

Shumate did not provide a concrete reason as to why she reduced Plaintiff’s work hours

beyond generally reiterating that overtime hours should be approved.

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21. Defendants refused to compensate Plaintiff for the additional overtime hours 

improperly removed by Shumate.

22. Based on Plaintiff’s conversations with Defendants and their management 

employees, including the admissions by Shumate, Plaintiff has reason to believe that 

Defendants altered the timesheets of her and other employees on a regular basis by reducing 

the number of clocked overtime hours.

23. Additionally, Defendants instituted a 30-minute automatic deduction for meal 

breaks. Defendants carried out this policy by manually altering the clock in and out times for 

meal breaks.

24. During these unpaid meal breaks Plaintiff and members of the Plaintiff class 

routinely performed work, again to the benefit of the employer, without pay for that time.

25. Oftentimes, due to facility volume and patient care, Plaintiff either was only 

able to take a short meal break of about 15 minutes or did not take a meal break at all.

26. In instances where Plaintiff was unable to take a meal break due patient needs, 

30-minutes would be deducted from those shifts by Defendants. Defendants would alter 

Plaintiff’s timesheets to reflect in and out times for meal breaks that equaled exactly 30-

minutes. When Plaintiff clocked meals herself during the rare instances in which she was able 

to take a meal break, the entries were never exactly 30-minutes apart.

27. In most instances, the work off the clock as described above should have been 

compensated at time and one-half the workers’ regular hourly rate because if the unpaid time 

was properly treated as compensable, Plaintiff and other members of the Plaintiff Class would 

have recorded over 40 hours in particular workweeks. In other limited instances, the unpaid 

time should have compensated at the workers’ regular hourly rates.

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28. Plaintiff, and members of the Plaintiff Class, on a regular basis worked in excess 

of forty (40) hours in a workweek without pay at a rate of time and one-half for all such hours 

pursuant to the requirements of the federal and state statutes herein relied upon.

29. This work performed by Plaintiff and members of the Plaintiff Class was work 

off the clock to the benefit of the employer without pay, in violation of the requirements of 

the federal and state statutes herein relied upon.

30. The total amount of hours worked off the clock by Plaintiff and members of the 

Plaintiff Class, and therefore the total number of regular and or overtime hours for which 

additional compensation is owed, is information substantially, if not completely, within the 

control and possession of Defendant in that Defendant recorded or should have recorded such 

hours pursuant to the record keeping requirements found in Title 29 CFR, Part 516. To the 

extent Defendants lack the records required by 29 CFR Part 516, Plaintiff and the Plaintiff 

class will be capable of providing reasonable estimates of that time, as permitted by law.

31. The claims brought herein by the named Plaintiff are identical or similar to the 

claims of other past and present employees who were subject to the non-compliant policies 

and practices alleged herein. Those past and present employees are entitled to receive Notice 

of these proceedings pursuant to either the FLSA or the Federal Rules of Civil Procedure 23,

and afforded opportunity to join their claims.

32. The non-compliant practices as alleged herein were part of a variety of practices 

and policies implemented and maintained by Defendants and are common to a group or 

“class” of past and present employees. Those past and present employees are entitled to 

receive Notice of these proceedings pursuant to either the FLSA or the Federal Rules of Civil 

Procedure 23, and afforded opportunity to join their claims.

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COUNT I

VIOLATION OF FAIR LABOR STANDARDS ACT

1-31. Paragraphs 1 through 31 are re-alleged and incorporated as though set forth fully 

herein as paragraphs 1 through 31 of this Count I.

32. Pursuant to the Fair Labor Standards Act, 29 U.S.C. §201 et seq the named 

Plaintiff, and all other Plaintiffs similarly situated, known and unknown, are entitled to 

compensation for all hours worked and compensation at a rate not less than one and one-half 

times the regular rate of pay for all hours worked in excess of forty (40) hours, in any week 

during the two (2) years preceding the filing of this action. 

33. Defendants have at all times relevant hereto failed and refused to pay 

compensation to their employees, including the named Plaintiff herein and all other Plaintiffs 

similarly situated, known and unknown, as described above.

WHEREFORE, Plaintiff, on behalf of herself and all other Plaintiffs similarly situated, 

known and unknown, respectfully requests this Court to enter an order:

(a) awarding back pay equal to the amount of all unpaid overtime compensation 

for the two (2) years preceding the filing of this Complaint, according to the applicable statute 

of limitations;

(b) awarding prejudgment interest with respect to the total amount of unpaid 

overtime compensation;

(c) awarding Plaintiff’s reasonable attorneys’ fees and costs incurred as a result of 

Defendant’s violations of the Fair Labor Standards Act; and,

(d) for such additional relief as the Court deems appropriate under the 

circumstances.

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COUNT II

WILLFUL VIOLATION OF THE FAIR LABOR STANDARDS ACT

1-33 Paragraphs 1 through 33 of Count I are realleged and incorporated as though 

set forth fully herein as Paragraphs 1 through 33 of Count II.

34. Defendants’ actions as complained of above were done with Defendants’

knowledge that the compensation policies and practices at issue were in violation of the 

statutes alleged, or with a reckless disregard for whether or not the policies and practices were 

in violation of those statutes. Through legal counsel as well as industry experience and 

custom, Defendants possessed ample access to the regulations and statutory provisions 

relating to the state and federal laws recited herein, but either failed to seek out such 

information and guidance or did seek out the information and guidance but failed to adhere 

to the principles of compliance as stated.

35. Pursuant to the Fair Labor Standards Act, Plaintiff and all other employees 

similarly situated, past or present, are entitled to compensation at a rate not less than one and 

one-half times their regular rate of pay for all hours worked in excess of forty (40), in the three 

(3) years preceding the filing of this complaint.

WHEREFORE, Plaintiff, on behalf of herself and all other Plaintiffs similarly situated, 

known and unknown, respectfully requests this Court to enter an order:

(a) awarding back pay equal to the amount of all unpaid compensation for one (1) 

additional year, totaling three (3) years preceding the filing of this Complaint;

(b) awarding prejudgment interest with respect to the amount of unpaid overtime 

compensation;

(c) awarding Plaintiff’s reasonable attorneys’ fees and Court costs incurred as a 

result of Defendant’s violation of the Fair Labor Standards Act; and

(d) and such additional relief the Court deems appropriate under the circumstances.

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COUNT III

LIQUIDATED DAMAGES

UNDER THE FAIR LABOR STANDARDS ACT

1-35. Paragraphs 1 through 35 of Count II are re-alleged and incorporated as though 

set forth fully herein as Paragraphs 1 through 35 of Count III.

36. In denying the named Plaintiff and members of the Plaintiff Class 

compensation as described above, Defendants’ acts were not based upon good faith or 

reasonable grounds. Through legal counsel as well as industry experience and custom, 

Defendants possessed ample access to the regulations and statutory provisions relating to the 

state and federal laws recited herein, but either failed to seek out such information and 

guidance or did seek out the information and guidance but failed to adhere to the principles 

of compliance as stated.

37. The named Plaintiff and all other past and present employees similarly situated, 

known and unknown, are entitled to liquidated damages equal to the amount of all unpaid 

compensation, pursuant to 29 U.S.C. §260.

WHEREFORE, Plaintiff, on behalf of herself and all other Plaintiffs similarly 

situated, known and unknown, respectfully requests this Court to enter an order:

(a) awarding liquidated damages equal to the amount of all unpaid compensation;

(b) awarding Plaintiff’s reasonable attorneys’ fees and costs incurred as a result of 

Defendant’s violation of the Fair Labor Standards Act; and

(c) for such additional relief the Court deems appropriate under the circumstances.

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COUNT IV

SUPPLEMENTAL STATE LAW CLAIM

VIOLATION OF THE ILLINOIS MINIMUM WAGE LAW

1-37. Paragraphs 1 through 37 of Count III are re-alleged and incorporated as though 

set forth fully herein as Paragraphs 1 through 37 of this Count IV.

38. As described in the foregoing paragraphs, Defendants’ compensation policies 

and practices are in violation of the Illinois Minimum Wage Law, 820 ILCS §115/1 et seq.

39. The Illinois Minimum Wage Law provides that an employer who fails to pay 

the required amount of wages due an employee under the law shall be liable to the underpaid 

employee or employees for the unpaid wages and for an additional penalty in the amount of 

2% of the amount of such underpayments for each month following the date such 

underpayments remain unpaid.

40. Defendants’ failure to pay compensation as described above, has been willful 

and/or in bad faith. 

41. Plaintiff seeks certification of the Illinois Minimum Wage Law violations 

alleged herein pursuant to Federal Rule of Civil Procedure 23. 

WHEREFORE, Plaintiff, on behalf of herself and all other Plaintiffs similarly situated, 

known and unknown, respectfully requests this Court to enter an order: 

(a) declaring and decreeing Defendants’ compensation practices as described 

herein, and such other violations which may come to light during the prosecution of this 

matter, in violation of the provisions of the Illinois Minimum Wage Law;

(b) awarding an amount of damages, to be shown by the evidence, to which 

Plaintiff and other members of the Plaintiff Class are entitled;

(c) allowing this Court to retain jurisdiction of the case until such time it is assured 

Defendants have remedied the compensation policies and practices complained of herein and 

are determined to be in full compliance with the law;

 (d) directing Defendants to pay to Plaintiff’s reasonable attorneys’ fees, costs, and 

litigation expenses, as provided by statute;

(e) for such additional relief the Court deems just and appropriate under the 

circumstances.

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COUNT V

SUPPLEMENTAL STATE LAW CLAIM

VIOLATION OF THE ILLINOIS WAGE PAYMENT AN COLLECTION ACT 

1-41. Paragraphs 1 through 41 of Count IV are re-alleged and incorporated as though 

set forth fully herein as Paragraphs 1 through 41 of this Count IV.

42. Plaintiff, and members of the Plaintiff Class, were each an “employee” under 

the IWPCA, 820 ILCS § 115/2.

43. Plaintiff, and members of the Plaintiff Class, were not exempt from the 

IWPCA’s protections, 820 ILCS § 115/1, et seq.

44. Defendants were each an “employer” under the IWPCA, 820 ILCS § 115/2.

45. During the employment of the named Plaintiff, and members of the Plaintiff 

Class, Defendants systemically and improperly deducted money from the pay of the named 

Plaintiff and members of the Plaintiff Class which Defendants had agreed would be paid, by 

way of unilaterally and improperly manipulating the timesheets of Plaintiff and the Plaintiff 

Class in violation of the IWPCA. Plaintiff, and members of the Plaintiff class, as employees, 

were entitled to be paid their earned wages for work performed for the exclusive benefit of the 

employer. Defendants failed to tender Plaintiffs, and members of the Plaintiff Class, their 

earned compensation in accordance with the Act.

WHEREFORE, Plaintiff, on behalf of herself and all other Plaintiffs similarly situated, 

known and unknown, respectfully requests this Court to enter an order awarding:

(a) Judgment in an amount to be determined at trial for all of the earned wages, 

agency withholding deposits and final compensation due;

(b) Statutory interest damages in the amount of two percent (2%) per month of the 

amount of underpayments; 

(c) directing Defendants to pay to Plaintiff’s reasonable attorneys’ fees, costs, and 

litigation expenses, as provided by statute;

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(d) for such additional relief the Court deems just and appropriate under the

circumstances.

COUNT VI

VIOLATION OF FAIR LABOR STANDARDS ACT

RETALITORY DISCHARGE

 1-45. Paragraphs 1 through 45 of Count V are realleged and incorporated as though 

set forth fully herein as Paragraphs 1 through 45 of this Count VI. 

46. Plaintiff was fired by Defendants in retaliation for filing a complaint regarding 

Defendants’ improper timesheet alterations and denial of overtime wages.

47. In late November, following Plaintiff’s conference call with Defendants 

regarding her complaint of altered timesheets, Plaintiff filed a wage claim with the Illinois 

Department of Labor (“IDOL”).

48. On February 3, 2020, the IDOL notified Defendants of Plaintiff’s wage 

complaint. The IDOL advised Defendants that they had 30 days to respond to Plaintiff’s 

complaint.

49. On February 7, 2020, Plaintiff was terminated by Defendants, specifically by 

Defendant Shumate in a meeting with Defendants’ other supervisors and management 

employees.

50. Defendants told Plaintiff she was being terminated for purchasing a LINK card 

for a patient. Plaintiff vehemently denied the allegations to Defendants and stated that she 

had knowledge of the employee that had purchased the card for the patient. Defendants 

followed through with their termination of Plaintiff. Upon information and belief at the time 

this Complaint was filed, the employee that had in fact purchased the LINK card for the 

patient remains in Defendants’ employ.

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51. Defendants accused Plaintiff of violating facility policies only after receiving 

notice of her IDOL complaint.

 52. In direct retaliation for Plaintiff asserting her rights under the FLSA and IMWL

as described above, Defendants retaliated against Plaintiff.

 53. Pursuant to Fair Labor Standards Act, 29 U.S.C. §215(a)(3), it is illegal for an 

employer, or an employer through other appointed agents and affiliates, to retaliate or 

discriminate against an employee for asserting her rights for back overtime wages as described 

above. 

 WHEREFORE, Plaintiff respectfully requests this Court to enter an order: 

(a) awarding back pay equal to the amount of all wages lost by Plaintiff as a result 

of the retaliatory acts complained of herein;

(b) awarding prejudgment interest with respect to the total amount of all lost wages;

(c) awarding Plaintiff’s reasonable attorneys' fees and costs incurred as a result of 

Defendant’s violation of the Fair Labor Standards Act; 

(d) awarding punitive damages against Defendants in an amount in excess of One 

Million Dollars ($1,000,000);

(e) for such additional relief as the Court deems appropriate under the 

circumstances.

Respectfully submitted,

Electronically Filed 04/20/2020

/s/ John W. Billhorn

John William Billhorn

BILLHORN LAW FIRM

53 West Jackson Blvd., Suite 401

Chicago, IL 60604

(312) 853-1450

Attorney for Plaintiff, and all other 

Plaintiffs similarly situated, known or 

unknown.

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