Holt v. Battle Creek

Plaintiffs, battalion chiefs in Battle Creek’s fire department, were responsible for many administrative tasks. While they did not have direct authority to make hiring and firing decisions, they conducted performance evaluations and approved vacation requests. Plaintiffs’ suggestions and recommendations as to hiring, firing, advancement, or promotion of other employees were given "particular weight.” Plaintiffs were required to periodically serve on “standby” duty and be “on call” from 5:00 pm until 8:00 am the following morning for seven days. Plaintiffs received 1.5 hours of pay for each day of standby duty, plus overtime pay for hours worked if they were called back to active duty while on standby. The individual on standby duty was required to monitor a pager and a radio, answer phone calls, and help handle problems. Plaintiffs were occasionally required to respond to the scene of a fire while on standby duty. Plaintiffs filed a complaint alleging violations of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201, by failing to pay overtime. The district court ruled and the Sixth Circuit affirmed that Plaintiffs were exempt from the FLSA’s overtime pay requirement under the executive exemption. Ample evidence supported a finding that Plaintiffs’ primary duty was managerial in nature. View "Holt v. Battle Creek" on Justia Law