In the case of Riley v. Town of Basin, Jack C. Riley appealed the denial of his claim for overtime compensation under the Fair Labor Standards Act (FLSA). His employer, the Town of Basin, Wyoming, argued that Riley was an exempt employee under the FLSA and that he had prevented the Town from knowing about the extra hours he worked.
Riley was initially hired as an Office Manager but his title and job duties changed the following year. The Town changed Riley’s title to Clerk/Treasurer, Business Manager and implemented a policy that required prior authorization for employees to work more than 40 hours per week. Riley submitted weekly time cards, but he did not claim overtime hours for the additional time he worked.
Riley presented evidence to support his claim for unpaid overtime compensation and to rebut the Town’s defenses. However, the court held that Riley failed to prove that he worked over 40 hours per week. The court also determined that Riley qualified as an exempt executive employee. It based this conclusion on factors such as Riley’s salary, his primary duty of managing the Town’s business affairs, his supervision of employees, and his exercise of discretion in his job.
However, the appellate court determined that the district court used the wrong legal standards in its decision. The district court considered tasks that did not show managerial responsibilities in determining Riley’s exempt status. The appellate court also disagreed with the district court’s interpretation of Riley’s burden of proof for the number of hours worked. It stressed that the burden should not be too difficult for the employee, and if the employer cannot provide precise evidence, a fair approximation of damages can be made.
Based on these findings, the appellate court remanded the case to the district court to apply the correct legal criteria in determining Riley’s entitlement to overtime compensation.
Key lessons from this case:
- Job titles and duties play a significant role in determining overtime eligibility under the FLSA.
- Employers bear the burden of proving the exemption by clear and affirmative evidence.
- Submitting time cards without claiming overtime hours may affect an employee’s ability to seek unpaid overtime compensation.
If you want to know more about overtime regulations, read our guide on Wyoming Overtime Laws.
