In the case of Donahue v. Trial Court of the Commonwealth of Massachusetts, William Donahue, a court officer under the Trial Court of the Commonwealth of Massachusetts (Trial Court), alleged that he was not paid compensation for his hours worked overtime. Donahue claims that this is a violation of the federal Fair Labor Standards Act (FLSA), the Massachusetts Wage Act, and the Massachusetts overtime law.
The Trial Court sought to dismiss these allegations, stating that “sovereign immunity” barred the claim. The Trial Court stated that Donahue’s FLSA claims were blocked by sovereign immunity. The court judge agreed with the Trial Court.
The court also analyzed Donahue’s claims under the Massachusetts Wage Act. This Wage Act required that employers pay wages to certain employees, including “mechanics, workmen, and laborers” or those employed in a “penal or charitable institution. The court found that Donahue’s job as a court officer did not fall within any of that category. The courthouse was also not considered a penal institution.
Lastly, the court claimed that Donahue’s allegation of violation of the Massachusetts overtime law is invalid. The court stated that the state overtime law does not provide a private right of action, which means that individuals cannot bring a lawsuit solely based on the violation of this law.
Overall, the court dismissed all of Donahue’s common-law allegations.
Key lessons from this case:
- Sovereign immunity protects the government from being sued without its consent.
- Massachusetts overtime law does not provide a private right of action, meaning individuals cannot bring a lawsuit under this statute to recover unpaid overtime.
- The Massachusetts Wage Act governs the payment of wages to employees in the state.
If you want to know more about overtime regulations, read our guide on Massachusetts Overtime Laws.
