Carranza v. Red River Oilfield Services, LLC, 4:15-cv-03631

Harley Carranza worked for Red River Oilfield Services as an Electromagnetic Inspector from June 2013 to November 2015 and was paid a salary plus commission.
Carranza sued under the FLSA alleging unpaid overtime for hours over 40 per week.
Red River moved for summary judgment asserting the executive and highly-compensated-employee exemptions applied.
The court granted summary judgment for Red River, concluding Carranza’s primary duties were managerial/supervisory and met exemption criteria.
Carranza filed a Rule 59(e) motion seeking relief/new trial, alleging material discrepancies between the owner Rick Blankenship’s declaration and deposition that would create a fact issue about whether Carranza was a "blue collar" manual worker.
The court reviewed the deposition and declaration, found no material discrepancies that would create a genuine issue of material fact, and denied the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Blankenship’s declaration conflicts with his deposition such that summary judgment should be vacated	Blankenship’s deposition contains statements that contradict his declaration and raise factual disputes	No material discrepancies exist between the deposition and declaration; testimony cited does not undermine exemptions	Court: No material discrepancies; motion denied
Whether Carranza is a “blue collar” worker for purposes of the highly-compensated-employee exemption	Carranza performed manual inspection work, so the non‑manual primary duty requirement is unmet	Carranza’s primary duty was managing and supervising the inspection crew, satisfying exemption criteria	Court: Primary duty was management; exemption applies
Whether the executive exemption applies	Carranza implicitly argues he did not perform management duties sufficient for the exemption	Red River argues Carranza met executive exemption elements (salary, management of subdivision, directed at least two employees, influence over personnel)	Court: Executive exemption satisfied; summary judgment proper
Whether newly discovered evidence or manifest error warrants relief under Rule 59(e)	The deposition excerpts constitute newly discovered evidence or show manifest factual error	No new evidence or manifest error; deposition was available and considered and does not change outcome	Court: Rule 59(e) relief denied

Templet v. HydroChem, Inc., 367 F.3d 473 (5th Cir. 2004) (Rule 59(e) relief is extraordinary; cannot rehash prior arguments)
In re Rodriguez, 695 F.3d 360 (5th Cir. 2012) (Rule 59(e) permits correction of manifest errors or presentation of newly discovered evidence)
In re Transtexas Gas Corp., 303 F.3d 571 (5th Cir. 2002) (standards on reconsideration and newly discovered evidence)
Dalheim v. KDFW-TV, 918 F.2d 1220 (5th Cir. 1990) (primary duty analysis focuses on duties of principal value to employer)
Malacara v. Garber, 353 F.3d 393 (5th Cir. 2003) (nonmovant must specifically present evidence in summary judgment response; court need not sift the record)