Babbitt v. Target Corporation is a collective action in the District of Minnesota involving salaried employees at Target. Tammy Babbitt (Babbitt) worked as an executive team leader, a position Target Corporation classified as exempt under the Fair Labor Standards Act (FLSA). Because of that classification, she was salaried and did not receive overtime pay.
Babbitt argued that her primary duty at Target was not management. She said she regularly stocked shelves, ran registers, unloaded trucks, cleaned, set displays, and filled online orders. She also claimed that her supervisors controlled staffing, budgets, and discipline, leaving her little discretion in making decisions.
Target Corporation argued that Babbitt’s role was managerial. The company pointed to her responsibility for leading team members, enforcing compliance, contributing to staffing decisions, and opening the store.
The court found genuine disputes about whether Babbitt’s primary duty at Target was management or manual labor. As a result, the judge denied Target’s motion for summary judgment. The lawsuit remains active, and the misclassification claims will proceed through further court proceedings.
Lessons learned from the case:
- Job titles and salaries at Target Corporation, or any employer, do not determine exemption status—actual duties do.
- The “primary duty” test under the FLSA depends on the work employees spend most of their time doing.
- Employers must document managerial discretion and authority if they rely on the executive exemption.
- Courts are unlikely to dismiss salaried employee misclassification cases when daily duties are in dispute.
If you want to know more about salaried employee rights, read our guide on What are my rights as a salaried employee in Minnesota?
