By Amanda Whorton
On December 18, 2015, the Fourth Circuit issued a published opinion in the civil case Williams v. Genex Services. The court affirmed the district court’s award of summary judgment to the defendant, Genex Services, LLC (“Genex”), in holding that Nancy Williams (“Williams”) was exempt from the mandatory overtime provisions of the Fair Labor Standards Act (“FLSA”).
Williams’ Job Duties
Genex provides services to clients that focus on controlling health care and disability costs, as well as ensuring that workers have access to quality health care. Genex makes sure that injured workers return to work as quickly and as cost-effectively as possible.
Williams works as a Field Medical Case Manager for Genex and began working there in 2011. She is paid a salary by Genex and for 2012 and 2013, that salary was over $80,000. As part of Williams’ job, she must be a licensed Registered Nurse (“RN”).
Williams develops individual care plans for injured workers, reviews their medical records, and interviews them about their conditions. She coordinates injured workers’ medical care and communicates with various groups to assess whether these workers are receiving appropriate care. Williams makes recommendations concerning alternate forms of treatment and provides commentary and suggestions on the injured workers’ conditions. She has two supervisors, but rarely has contact with them.
The FLSA Requires That Employers Pay Overtime Compensation
The FLSA requires that employers pay overtime compensation to employees who work more than 40 hours during a seven-day period, unless the employer falls under one of the FLSA’s exemptions. One of these exemptions is the “learned professional” exemption. The relevant Department of Labor regulation states that for an employee to fall under this exemption, the employee’s primary duty must be the performance of work “requiring advanced knowledge . . . in a field of science or learning,” that is “customarily acquired by a prolonged course of specialized intellectual instruction.”
The District Court Granted Defendant’s Motion for Summary Judgment
Genex filed a motion for summary judgment, which the district court granted because it agreed that Williams was a learned professional and therefore fell under the FLSA exemption. Williams argued that her duties consisted only of clerical, nondiscretionary, and routine work, but the district court rejected that argument. The district court concluded that Williams performed work requiring advanced knowledge, as she advised injured workers on their medical conditions and made her own commentary and suggestions. She was not closely supervised and had a great degree of discretion in performing her duties. The district court further reasoned that because Williams was a licensed RN, she performed work in a field of science that is customarily acquired by a prolonged course of specialized intellectual instruction.
The Fourth Circuit Affirmed
The Fourth Circuit affirmed the district court’s grant of summary judgment to Genex in holding that Williams’ position was properly classified under the “learned professional” exemption in the FLSA. The Fourth Circuit reasoned that Williams regularly had to use her skills, training, and knowledge as a RN to perform her duties, she exercised her own discretion on a daily basis, and was not closely supervised. Therefore, Williams fell under the “learned professional” exemption and was not subject to overtime compensation.
