Over the past several months, it’s clear the company has been consistently laying off employees — roughly the same number each month, almost like clockwork. While leadership has publicly acknowledged these reductions, there are a few things don’t fully add up.
Where’s the WARN Notice? So far, I haven’t found any WARN notice filings from our company — at either the federal or state level. This is unusual given the scope and repetition of the layoffs.
Why WARN Notices Matter
• Transparency: WARN notices are public and include specific details (locations, job roles, counts). Avoiding this filing prevents employees from having a full understanding of what’s happening.
• Rights & Pay: If WARN rules apply and weren’t followed, affected employees may be legally entitled to back pay and benefits for the 60-day notice period.
• Legal Risk: Staggering layoffs to avoid crossing the 50-person threshold may seem clever on paper, but courts can still view it as part of a broader layoff plan. That’s risky — for the company and for us.
200 Employees Terminated Per Month — For Two Years
Internal data and broader reporting indicate that roughly 200 employees have been leaving the company every month for the last two years. That adds up to 4,800+ departures.
Some of this may be natural attrition — but this figure closely matches reports of involuntary terminations, suggesting it’s not just people quitting on their own.
Additionally, the company rolled out a voluntary severance program — which about 600 employees accepted — under conditions that felt like “quit now or risk being laid off later.”
Meanwhile, many departments have been offshored, with knowledge transfer efforts happening in parallel.
What the DOL and Courts Say About “Voluntary” Severance
According to the U.S. Department of Labor:
“Voluntary departures, retirements, or resignations generally do not count, unless the employee departure is caused by the employer and qualifies as an employment loss.”
Source: DOL WARM Act FAQ
Regulations: 20 CFR: 693.3(f)
So if it was implied that employees were to “Take the package now or be on the next layoff list,”
That may legally count as a layoff, not a voluntary exit. And if those numbers weren’t included in WARN reporting? That’s a serious issue.
Staggered Layoffs = WARN Evasion?
Federal law also explicitly prohibits breaking up layoffs to avoid WARN thresholds. According to 20 CFR § 639.5(a)(2):
“An employer may not evade the purpose of the Act by staggering terminations… if they are part of a common layoff plan.”
If 200 employees are being terminated monthly — even across departments or locations — and no WARN notices are being filed, that strongly suggests a strategy designed to stay just under the legal reporting threshold.
For Reporters or Watchdogs Monitoring This Forum:
How has no one picked up this story?!?
This situation potentially involves:
• Thousands of U.S. terminations over 24 months
• A “voluntary” severance program used to disguise layoffs
• No public WARN filings (despite the scale)
• A clear pattern of offshoring and workforce consolidation
• Potential WARN Act non-compliance through structuring and timing.
• Oh and don’t forget the philanthropic award the company won a few years ago for committing to increasing local jobs in St.Louis by 10%.