This Ganz v. Alaska Airlines, Inc. case involves a dispute between Alaska Airlines and some of its employees over the interpretation of statutory exemptions from the overtime provision of the Alaska Wage and Hour Act (AWHA). The employees who work in Prudhoe Bay argued that they were entitled to overtime payments for work over 40 hours a week or 10 hours a day. Alaska Airlines contended that their work schedule, as defined in their collective bargaining agreements (CBA), was exempt from AWHA’s overtime provision. The CBA included side letter agreements stating that the employees worked 14 consecutive 12-hour days, followed by 14 days off, and received overtime payments only for hours worked more than this schedule.
The main issue was the interpretation of AS 23.10.060(d)(13). The employees argued for a narrow definition of a “flexible work hour plan” that would include only schedules of 40 hours a week or 10 hours a day. However, the court concluded that the plain language of the statute and its legislative history supported a broader interpretation of the exemption.
The court analyzed the statutory context and compared it to another exemption in AS 23.10.060(d)(14), which applied to voluntary flexible work-hour plans negotiated directly between an employee and an employer. The court found that the absence of similar restrictions in subsection (d)(13) indicated the legislature’s intent not to limit the exemption for plans included in CBA.
Based on their analysis, the court held that the employee’s work schedule, included in their CBA, was exempt from AWHA’s overtime requirements. Therefore, the superior court’s decision to grant summary judgment in favor of Alaska Airlines was affirmed.
Key lessons from this case:
- The terms and provisions of these agreements can affect the applicability of overtime laws and exemptions.
- The AWHA includes statutory exemptions that can impact the application of overtime provisions.
- Side letter agreements, incorporated into CBAs, can provide variations in work and pay schedules based on unique working conditions.
Learn more about Alaska Labor Laws through our detailed guide.
