In the case of Melton v. Tippecanoe County, James Melton, a former employee of the Tippecanoe County Surveyor’s Office (County), alleged that he was not properly compensated for his overtime hours. Melton claimed that this was a violation of the FLSA.
Melton had asked his supervisor if he could take a class during work hours and make up for the missing time by having shorter lunches and coming to work earlier. Melton’s supervisor denied his request and said that the missing time would be considered “unpaid”.
To solve that, Melton worked through his lunch hour one day and arrived early on three days during the week. He was compensated for his extra hours but was fired later on as he went against his supervisor’s orders.
After being fired, Melton decided to file a lawsuit alleging that his timecards did not properly record the hours he had worked throughout his employment. Melton claimed that his timecards were being altered to only a maximum of 37.5 hours per week and he also that he was not compensated for the times he started work before 8 am.
Melton presented a spreadsheet that he created from memory as evidence to support his claims that he deserved overtime pay but the County argued that this was unreliable.
The district court ultimately granted a summary judgment that favored the County as Melton did not have enough to establish an FLSA violation. The court decided that Melton could not provide evidence to support his spreadsheet.
Although Melton had decided to appeal this summary judgment, the Court of Appeals also agreed to grant the summary judgment to the County.
Key lessons from this case:
- Testimony or evidence provided by the employee must be credible and plausible, and unsupported claims may be rejected without a trial.
- Despite working overtime without permission, an employer still needs to pay for the overtime hours an employee works.
- Melton’s termination is not considered retaliation for alleged overtime violations but was for disobeying his superior’s orders.
If you want to know more about overtime regulations, read our guide on Indiana Overtime Laws.
