Employee Fails to Prove Willful Misconduct in Overtime Pay Lawsuit

In the case of Bey v. Dynamic Computing Services (DCS) Corp., Debra Bey filed a complaint against DCS for failure to compensate her and other employees for working overtime. Bey was hired by DCS to work at Alaska Regional Hospital as a consultant on a medical software transition project. DCS sought summary judgment against Bey’s allegations.

DCS argued that Bey’s claim was time-barred and that she was exempt from overtime pay as a computer employee. Bey agreed to the statute of limitations issue but contends that the extended 3-year period applied due to DCS’s willful violation. However, the court determined that there was no evidence of willfulness on DCS’s part and that the claim fell outside the standard 2-year limitations period.

The court also found that Bey’s position qualified as an exempt computer employee under the FLSA. Therefore, the court granted DCS’s motion for summary judgment and dismissed Bey’s claims.

Key lessons from this case:

  • Employees have a limited time frame to file overtime claims. There is a standard two-year limitation period which extends to 3 years for willful violations.
  • To establish a willful violation, there needs to be evidence that the employer disregarded the possibility of an FLSA violation.
  • The classification of an employee as exempt can be considered reasonable if based on the job description and duties performed.

Learn more about Alaska Labor Laws through our detailed guide.

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