In the case of Smith v. Ochsner Health System, Daniel Smith filed a lawsuit against his former employer, Ochsner Health System (Ochsner), for allegedly not providing him with compensation for the overtime hours he worked. Smith was hired as an organ procurement coordinator and was responsible for being the main point of contact between the hospital and the Louisiana Organ Procurement Agency.
Smith’s duties included evaluating potential organ donors, communicating with surgeons, arranging transportation for organs, and completing necessary reports. Smith claimed that this demanding workload was stressful and led to health issues, eventually forcing him to resign.
Ochsner argued that Smith was exempt from overtime pay under the Fair Labor Standards Act (FLSA) as he was a highly compensated and also administrative employee. The court examined the highly compensated employee (HCE) exemption and its requirements and noted that Smith met them.
The following analysis was whether Smith was exempt as an administrative employee. Ochsner claimed that Smith’s role as an organ procurement coordinator involved activities that were directly related to the hospital’s operations. Smith argued that his involvement in procurement was minimal and should not be considered as exempt.
After considering the arguments from both Smith and Ochsner, the court concluded that Smith did not meet the criteria for entitlement to overtime pay under the FLSA. As a result, the court ruled in favor of Ochsner.
Key lessons from this case:
- The HCE exemption applies to employees who meet specific criteria, including being compensated at least $100,000 annually, regularly performing exempt duties, and engaging in office or non-manual work as their primary duty.
- The administrative employee exemption applies to employees whose primary duties involve performing office or non-manual work directly related to the business operations of the employer or the employer’s customers.
- Employers must ensure that employees meet all the criteria for a claimed exemption to avoid potential liability for unpaid overtime wages.
If you want to know more about overtime regulations, read our guide on Louisiana Overtime Laws.
