Greg Holaway v. Stratasys, Inc., 771 F.3d 1057

Holaway was a salaried Field Service Engineer (FSE) for Stratasys from 2006–2012; Stratasys classified FSEs as exempt from FLSA overtime pay.
Holaway worked remotely, was on call during the workweek, traveled to customer sites to install/repair 3D printers, and received a salary with no overtime.
Holaway emailed coworkers in Feb. 2012 complaining FSEs were expected to work 45–60 hour weeks; he was later terminated for violating company protocol.
In depositions Holaway estimated typical weekly hours between 45 and 70, variously stating 60–70, 60, or 62–70 hours per week, but gave no contemporaneous timesheets or week-by-week records.
Because Stratasys classified him as exempt, it did not keep precise hourly records; Holaway sued under the FLSA for unpaid overtime and sought damages based on an assumed 60 hours per week every week of employment.
The district court granted summary judgment for Stratasys, finding Holaway offered only vague, inconsistent estimates and no evidence tying overtime to specific weeks; the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Holaway proved he worked >40 hours in any given workweek	Holaway argued he typically worked ~60 hours/week and thus is owed unpaid overtime	Stratasys argued Holaway offered only vague, inconsistent estimates and no specific week-by-week evidence	Held for Stratasys: Holaway failed to provide sufficient evidence of overtime for any specific week
Applicability of relaxed proof standard when employer fails to keep records	Holaway relied on the relaxed standard allowing reasonable inference from employee testimony	Stratasys contended Holaway still must present sufficient probative evidence of amount and extent of overtime	Held: Relaxed standard applies, but Holaway’s evidence was too vague to meet it
Whether classification as exempt relieves employer of recordkeeping	Holaway argued lack of records favors allowing inference for overtime	Stratasys noted classification meant no precise records but emphasized plaintiff’s burden to show overtime	Held: Exempt classification meant employer lacked records, but plaintiff still must supply sufficient evidence; he did not
Whether summary judgment appropriate given record	Holaway contended disputes over hours preclude summary judgment	Stratasys argued no genuine dispute of material fact due to insufficient evidence	Held: Summary judgment affirmed—no genuine issue because evidence could not support a reasonable jury finding overtime

Tusing v. Des Moines Indep. Cmty. Sch. Dist., 639 F.3d 507 (standard of review for summary judgment)
Davis v. Jefferson Hosp. Ass'n, 685 F.3d 675 (evidence and inferences viewed in favor of nonmoving party)
Mann v. Yarnell, 497 F.3d 822 (nonmoving party must provide sufficient probative evidence)
Torgerson v. City of Rochester, 643 F.3d 1031 (no genuine issue when record cannot lead a rational trier of fact to find for nonmoving party)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (burden on employee to prove unpaid work; relaxed proof standard when employer fails to keep records)
Fast v. Applebee's Int'l, Inc., 638 F.3d 872 (employee burden to prove uncompensated work under FLSA)
Dole v. Tony & Susan Alamo Found., 915 F.2d 349 (employees may recover based on most accurate basis possible when employer failed to keep records)
Carmody v. Kansas City Bd. of Police Comm'rs, 713 F.3d 401 (once employee shows uncompensated work and reasonable inference of amount, burden shifts to employer)