Hines v. State Room, Inc., 665 F.3d 235

Plaintiffs Christine Hines, Mary A. O’Connor, and Jessica Leporacci were sales managers at the State Room and Belle Mer, affiliated banquet facilities, with Longwood Events providing management services.
They alleged they were owed overtime under the FLSA and state laws, contending they were non-exempt administrative employees due to discretion and independent judgment in their duties.
Defendants moved for summary judgment, arguing plaintiffs fell within the administrative exemption under 29 U.S.C. § 213(a)(1) and 29 C.F.R. § 541.200 et seq.; district court agreed.
The district court found plaintiffs' duties involved substantial discretion in assembling custom events, client relationship management, and tailoring proposals within predefined price structures.
The district court acknowledged some disputes of fact but held that, viewed in the plaintiffs’ favor, they still exercised discretion and independent judgment sufficient for the exemption.
This First Circuit appeal followed, with the court reviewing de novo the district court’s summary judgment determination in light of the FLSA regulations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether employees meet the administrative exemption	Hines group asserts insufficient discretion for exemption.	Defendants contend duties meet admin exemption under 541.200(a)(3).	Exemption satisfied; employees exercised discretion and judgment.
Role of discretion factors under 541.202 in this case	Discretion was limited; tasks lacked financial authority.	Independent judgment shown in designing and tailoring events within options.	Courts must assess facts; substantial discretion present, not rigidly required by every factor.
Key facts support for primary duty being related to management or general operations	Work primarily involved client contact, not management.	Work directly related to running and servicing the business through event design and client management.	Second prong met; primary duty relates to management/general operations.
Impact of resumes and submitted proposals on discretion ruling	Resumes and documents are unreliable for showing discretion.	Resumes corroborate the discretionary nature of duties.	Resumes admissible; cannot negate substantial discretion.

Reich v. John Alden Life Ins. Co., 126 F.3d 1 (1st Cir. 1997) (discretion and exemption analysis for marketing employees)
Cash v. Cycle Craft Co., 508 F.3d 680 (1st Cir. 2007) (discretion necessary for administrative exemption)
John A. Alden Life Ins. Co., 126 F.3d 1 (1st Cir. 1997) (customer-facing roles can involve sufficient discretion for exemption)
In re Novartis Wage & Hour Litigation, 611 F.3d 141 (2d Cir. 2010) (examines application of discretion factors under 541.202)
Arnold v. Ben Kanowsky, Inc., 361 U.S. 388 (1960) (remedial exemptions narrowly construed)