In the case of Boose v. FNP, Inc., Travis Boose filed a complaint against First National Pawn (FNP) for failure to pay overtime wages. Boose and other employees were classified as non-exempt under the Fair Labor Standards Act, meaning they were legally entitled to overtime pay. Boose claimed that he and other employees entered into employment agreements that did not reflect their actual schedule or rate of pay. They were paid a fixed monthly salary regardless of the number of hours they worked. Boose further alleged that they were required to arrive at work early, stay late regularly, and occasionally work on scheduled days off without receiving additional compensation for the extra hours worked.
FNP argued that Boose did not identify a specific workweek or provided sufficient factual details to support a plausible claim for unpaid overtime. FNP argued that Boose’s allegations were too conclusory and lacked factual specificity. The court agreed with FNP that Boose’s complaint and proposed amended complaint do not contain sufficient detail about the length and frequency of unpaid work to support a reasonable inference that they worked more than 40 hours in a given week. Boose’s general allegations that employees were required to arrive early, stay late, and occasionally work on scheduled days off were deemed insufficient.
Ultimately, the court recommended granting FNP’s motion to dismiss the FLSA claim but allowed Boose to file an amended complaint to address the pleading deficiencies.
Key lessons from this case:
- Employment agreements should accurately reflect the employee’s actual schedule and rate of pay.
- Paying employees a fixed monthly salary regardless of the number of hours worked does not absolve employers from their obligation to pay overtime wages for hours exceeding the statutory threshold.
- To establish a plausible claim for unpaid overtime, it is important to provide sufficient factual details regarding the length and frequency of unpaid work.
If you want to know more about overtime regulations, read our guide on Montana Overtime Laws.
