Case No. 19-CV-03389 in the United States District Court for the Northern District of Illinois, Eastern Division

The Notice of Class Action Settlement is to inform you that a Class Action settlement has been reached between and Parties and approved by the United States District Court for the Northern District of Illinois.  This Notice explains the Settlement and gives you instructions on how to claim your settlement award. Please read this Notice carefully.

If you were employed by SCR Medical Transportation as a Driver of a medical van at any time after May 20, 2016 and experienced waiting in line prior to clocking in with the MDT device in your vehicle at the start of your shift or experienced time waiting in line after you clocked out with the MDT device at the end of your shift, and that waiting time exceeded 15 minutes per shift, you are eligible to participate in this settlement.

On May 20, 2019, Thomas Goodlet and Adrienne Williams (“Plaintiffs”) filed a Class Action case alleging, among other things, that SCR Medical Transportation, Inc. (“SCR” or “Defendant”) failed to compensate Drivers of medical vans for time spent waiting in line prior to the Driver clocking in with the MDT device in the van at the start of their shifts and failed to compensate Drivers time spent waiting in line after they clocked out with the MDT device at the end of their shift, and that the waiting time waiting time exceeded the 15 minutes per shift that SCR allotted.  SCR has denied these allegations, and the Court in this case has not decided in favor of either Plaintiff or SCR. Instead, Plaintiffs and SCR, through their attorneys and with the help of the Court, negotiated a settlement of this dispute so as to avoid having to face the uncertainties and substantial costs of a trial. SCR records reflect that you were employed as a Driver by the Company after May 20, 2016 and that you were worked shifts that included wait time as described above.  Thus, you are eligible to participate in this settlement if you believe the wait time was in excess of fifteen (15) minutes per shift. The following information describes your options regarding participation in this case. PLEASE READ CAREFULLY.  THE OPTIONS DESCRIBED HERE IMPACT YOUR LEGAL RIGHTS.

            In order to participate in a share of this settlement, you must complete and sign the enclosed CLAIM FORM.  The process is described below.  Please read carefully, and if you wish to participate and receive your monetary award, sign and return the Claim Form.

Your legal rights will be affected whether you act or don’t act.

Please read the notice carefullyIt explains your legal rights and the options and deadlines necessary to exercise those rights.



Completing and timely returning the Claim Form enclosed in this mailing is the only way to get a settlement payment.   More on that is described below. Please read carefully.


The Settlement in this case consists of three (3) categories of claims – one under Chicago law, one under Illinois law, and one under federal law.  By completing, signing, and returning the Claim Form, you will waive and release SCR from all wage claims you have or may have associated with your employment.  Please read on – below there is a more detailed description about the rights you are releasing by participating in the settlement.


If you are unhappy with something about this settlement, you may write to the Court about why you do not believe the settlement is fair. This is called “objecting”.  Instructions on how to object are described below.


You may also request to speak at an upcoming hearing that will be held in Court in Chicago regarding the fairness of the settlement. Read below.


If you do nothing, then you will not get a settlement payment from this case.  If you do nothing, you still waive and release any claim for unpaid wages you may have under Chicago or Illinois law.  However, if you do not return a signed Claim Form in this case, you will release only your Chicago and Illinois law claims - you would still have rights remaining under the federal law claims.  More on this is described below.


SCR has at all times denied that it violated any laws, including the Fair Labor Standards Act, Illinois Minimum Wage Law, or the Chicago Minimum Wage Ordinance. However, in order to settle this lawsuit, SCR has agreed to pay up to $1,200,000 in Settlement Funds to:

The attorneys representing the Class Members will request of the Court a percentage of the money recovered on behalf of the Class.

Before your settlement award can be sent to you, the Court overseeing this case must give Final Approval of the settlement. Settlement Funds will be distributed only if the Court gives Final Approval and after any appeals are resolved.  The final approval process may take several months.  Please be patient.