Court Issues Favorable Decision on Executive and Administrative Exemptions
California employers litigating wage cases involving alleged misclassification of employees have a new and favorable published case in their arsenal. In Taylor v. United Parcel Service, Inc., a California Court of Appeal rejected a UPS supervisor's claims that he was improperly classified as an exempt employee and should have instead been paid overtime and ensured meal and rest breaks. The court held, as a matter of law, that the employee qualified for both the administrative and executive exemptions from overtime laws. The court further held that the employee did not have sufficient evidence to support his claims to even warrant a trial on the issues.
The Taylor case contains a lot of good language on issues pertinent to the administrative and executive exemptions, including issues surrounding authority to hire and fire (as pertains to the executive exemption) and the administrative/production worker dichotomy (as pertains to the administrative exemption). Notably, the court rejected a strict application of the administrative/production worker dichotomy as a bar to a finding of administratively exempt status.
Although the Taylor case is a positive decision for California employers on exempt/non-exempt issues, employers are still cautioned to carefully review their exempt classifications because the wage and hour litigation flood continues in California.