WILLIAMS v. GENEX SVCS., LLC, NO. 14-1966
Decided: December 18, 2015
In a case about entitlement to overtime pay under the Fair Labor Standards Act (FLSA) and Maryland Wage and Hour Law (MWHL), the Fourth Circuit found that Nancy Williams was employed as a professional, and thus, Genex Services, LLC (Genex) did not have to pay her overtime. On that basis, the Fourth Circuit upheld the District Court’s grant of summary judgment to Genex.
Williams began working at Genex in 2011 after Genex acquired her former employer. Genex provides “integrated managed care services” to employers and workers’ compensation insurers in an attempt to control the costs of health care and disability, ensure provision of quality health care, and improve workers’ ability to return to work. Williams, who was a registered nurse, and held several professional certifications, worked for Genex as a Field Medical Case Manager (FMCM). In this capacity, she worked with a variety of people, including attorneys, carriers, doctors, and employees to ensure that workers received quality health care, and were able to return to work.
In July, 2013, Williams sued Genex arguing that Genex violated FLSA and MWHL by not paying her overtime. The District Court granted summary judgment to Genex on the basis that Williams was a learned professional, and thus Genex was not required to pay her overtime. The District Court based this finding on the fact that Williams was a registered nurse, and required to be one to hold her position, that she did work requiring specialized knowledge, and that she used this knowledge to serve her clients while also using discretion in performing her job duties. Williams appealed to the Fourth Circuit.
The Fourth Circuit focused its analysis on Williams’s FLSA claim because the definition of professional in the FLSA and MWHL is the same, so if the FLSA claim failed because Williams was a professional, the MWHL claim would as well. The Fourth Circuit then noted that Department of Labor regulations define a professional employee as one who earns at least $455 per week, and whose primary job duty is work that requires advanced knowledge normally achieved through specialized learning, or which requires creativity. Here, Williams, who earned over $80,000 per year in 2012 and 2013, clearly met the salary requirements. The Fourth Circuit found that Williams also met the requirements of a job whose primary duty involved advanced knowledge. They noted that the job description Williams proved on her resume included “‘assessing patient needs,’” creating patient plans, analyzing data, and working with other professionals. Further, Williams routinely used her skills as a registered nurse in performing her job duties including coordinating medical care, teaching employees about their conditions, and suggesting alternate treatments. Williams did much of her work without supervision. On this basis, the Fourth Circuit found that Williams fit within the FLSA’s definition of a professional employee, and thus Genex was not required to pay her overtime. For this reason, the Fourth Circuit affirmed the District Court’s grant of summary judgment to Genex.
Katherine H. Flynn