Care Manager Denied Overtime Due to Nonprofit Status

In the case of Paczkowski, Katy v. My Choice Family Care, Inc., Katy Paczkowski, a care manager working for My Choice, filed a lawsuit claiming that My Choice did not provide overtime wages for hours worked more than 40 per week. My Choice, a private “managed care organization”, provided healthcare and related services to adults and seniors with disabilities. That being said, My Choice argued that as a nonprofit organization, it was not subjected to Wisconsin’s overtime regulations.

The court had to interpret provisions of Wisconsin’s administrative code to determine whether My Choice was exempt from the state’s overtime regulations. Since the legislature is ambiguous, the court relied on the language, structure, and context of the state regulations to determine whether or not My Choice would be exempt.

Ultimately, the court determined that My Choice, as a nonprofit organization, is not subject to Wisconsin’s overtime regulations. The court decided to grant My Choice’s motion to dismiss Paczkowski’s claims.

Key lessons from this case:
  • It is important to fully understand the language and interpretation of Wisconsin law to properly determine overtime eligibility.
  • The court needs to deeply analyze the context of nonprofit organizations in the Wisconsin Administrative Code, which shows how small characteristics in a business can alter its entitlement to certain benefits in the state legislature.
  • The court plays an important role in interpreting and clarifying unclear regulations when it comes to disputes about overtime eligibility.

If you want to know more about overtime regulations, read our guide on Wisconsin Overtime Laws.

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