MCLAUGHLIN v. United States
1:21-cv-01775
Fed. Cl.May 19, 2025Background
- Aaron McLaughlin and Anitha Williams, Senior Watch Officers at the ODNI, sued the U.S. government for failure to properly compensate them for overtime, alleging violations of the FLSA and the Back Pay Act.
- Plaintiffs claim their jobs were misclassified as FLSA-exempt from 2018-present, resulting in lesser overtime compensation.
- The ODNI classified plaintiffs as FLSA-exempt and assigned them to a non-standard, rotating work schedule labeled as "maxi-flex"—but not as a formal compressed or flexible work schedule authorized by law.
- Both parties moved for summary judgment on whether plaintiffs were properly classified as exempt and whether their work schedule qualified for alternative overtime calculation.
- The court found factual disputes over whether the plaintiffs’ team lead duties qualified for a FLSA exemption, but found as a matter of law that plaintiffs were not placed on a proper compressed or flexible schedule, entitling them to certain overtime calculations.
- The court partially granted summary judgment to plaintiffs on the work schedule issue, and denied summary judgment regarding the exemption issue, setting further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FLSA Exemption Status | Not exempt; no managerial discretion | Exempt under administrative exemption | Factual disputes prevent summary judgment; fact-finding required |
| Whether "Watch" Duty Qualifies for Exemption | Core, "production" function, not admin | Watch includes team lead, qualifies as admin work | "Watch" is production; does not satisfy administrative exemption |
| AWS (Alternative Work Schedule) Legality | Work schedule neither flexible nor compressed as required by statute | Schedule was "maxiflex"/non-standard, which qualifies | Schedule did not comply with statute; plaintiffs entitled to judgment |
| Overtime Pay Calculation | Entitled to overtime for >8 hours/day or >40/week under Title 5 | Only for officially authorized hours over 80-hour biweekly | Plaintiffs' hybrid schedule unauthorized; overtime must follow statutes |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Celotex Corp. v. Catrett, 477 U.S. 317 (burden on movant in summary judgment)
- Berg v. Newman, 982 F.2d 500 (burden of proof on government for FLSA exemptions)
- Mingus Constructors, Inc. v. United States, 812 F.2d 1387 (cross-motions for summary judgment evaluated independently)
- Dairyland Power Co-op. v. United States, 16 F.3d 1197 (summary judgment; viewing evidence in light most favorable to non-movant)
- Jay v. Sec’y of Dep’t of Health and Hum. Servs., 998 F.2d 979 (summary judgment function not to resolve factual disputes)