In the case of Murdock v. Skinner, Rosemary Murdock filed a lawsuit against Rosemary Skinner, and Health & Wealth Distributors (H&W). Murdock sought to recover unpaid overtime wages under the Fair Labor Standards Act (FLSA).
Murdock was hired by H&W to perform clerical work and assist with their business. Skinner, however, was a high-level distributor at ASEA, LLC, a multilevel marketing company. Ten months after Murdock started working for H&W, she enrolled in ASEA as a distributor under Skinner.
Skinner and H&W argued that Murdock was exempt from overtime pay under the FLSA as an administrative employee. They also argued that even if Murdock was classified as a regular employee, she would only be entitled to two years of damages as she failed to show that the misconduct was willful. That being said, Skinner and H&W filed for a summary judgment in their favor.
The court determined that Murdock failed to present enough evidence to show overtime pay violations. However, the court denied the argument of whether the administrative exemption applied to Murdock. In summary, the court granted the motion for summary judgment in favor of Skinner and H&W regarding the willfulness of violation but denied it regarding the administrative exemption.
The case still needed to address the issues of overall entitlement to overtime wages. The final ruling of this case is undetermined.
Key lessons from this case:
- The administrative exemption requires that the employee’s primary duty be directly related to the management or general business operations of the employer or the employer’s customers.
- Employees claiming willful violations of the FLSA must provide evidence that the employer either knew or showed reckless disregard for whether their conduct violated the statute.
- If an employer wilfully violates the FLSA’s overtime pay regulations, they can be held liable for up to 3 years of back wages.
If you want to know more about overtime regulations, read our guide on Utah Overtime Laws.
