Evans v. McClain of Georgia, Inc. is a legal case brought before the U.S. District Court for the Middle District of Georgia. Aric Evans, a Black employee who had worked at an industrial plant in Macon for eight years, sued his employer under Title VII of the Civil Rights Act, Section 1981, and the Fair Labor Standards Act (FLSA). He alleged that his termination and denial of overtime were the result of racial discrimination and misclassification.
Evans claimed that he was promoted to “assistant manager” and reclassified as a salaried employee not to reflect his actual duties, but to remove him from union protections and avoid paying overtime. Despite the title, Evans argued that he had no clearly defined managerial responsibilities and regularly worked over 40 hours a week without extra pay. He also asserted that he was terminated due to his race and the employer’s biased treatment of Black workers.
The court acknowledged Evans’s claims but ultimately granted summary judgment in favor of the employer. It found that Evans had insufficient evidence to prove discriminatory intent or that his salaried, supervisory role exempted him from overtime protections under the FLSA.
Lessons Learned from the Case:
- Simply giving an employee a managerial title and salary doesn’t automatically exempt them from overtime pay; their actual job duties must meet FLSA criteria.
- Employers must be cautious when converting hourly employees to salaried roles—especially during sensitive events like union activity—as it may be viewed as retaliatory or manipulative.
- Courts require clear, specific, and probative evidence to support claims of racial bias or disparate treatment—not just general dissatisfaction with management or hearsay.
- Even when decisions seem unfair or inconsistent, unless there’s proof of bias tied to a protected class (like race), courts are unlikely to side with the employee.
If you want to know more about salaried employee rights, read our guide on What are my rights as a salaried employee in Georgia?
