In the case, Colburn v. Dept. of Corrections that took place in March 2003, Joseph Colburn and thirty-nine other supervisors employed at the Eastern Correctional Institute (ECI) within the Division of Corrections of the Maryland Department of Public Safety and Correctional Services (DPSCS) filed a complaint with their employer.
They sought overtime pay at a rate of one and a half times their regular hourly wage for performing non-supervisory correctional duties beyond their regular forty-hour workweek. The supervisors argued that by performing these additional duties outside their normal schedule, they should be classified as non-exempt employees under the Fair Labor Standards Act (FLSA) and thus entitled to receive overtime compensation. However, instead of paying overtime, the DPSCS granted them compensatory time off, equivalent to the number of extra hours worked.
An Administrative Law Judge (ALJ) was assigned to the case and denied the supervisors’ complaint, stating that they were exempt employees under the FLSA and therefore ineligible for overtime pay. Both the Circuit Court for Somerset County and the Court of Special Appeals upheld this decision.
Key lessons from this case:
- The case highlights the importance of correctly classifying employees as exempt or non-exempt under the Fair Labor Standards Act (FLSA) to determine their eligibility for overtime compensation.
- Understanding job duties is crucial to determine if they qualify for overtime pay. In this case, the supervisors argued that their non-supervisory correctional duties made them non-exempt employees eligible for overtime.
- The case illustrates the process of pursuing a grievance and the subsequent legal proceedings involved. It demonstrates the importance of understanding the decisions made by administrative law judges and the appellate courts.
If you want to know more about overtime regulations, read our guide on Maryland Overtime Laws.
