809 F.3d 103
4th Cir.2015Background
- Plaintiff Nancy Williams, a registered nurse employed as a Field Medical Case Manager (FMCM) by Genex, sued under the FLSA and Maryland Wage and Hour Law claiming unpaid overtime; district court granted summary judgment for Genex and Williams appealed.
- Williams is salaried (≈ $81–83K/year), required by Maryland to be an RN with certifications, and performs case assessments, develops individualized care plans, attends appointments, communicates with providers/insurers/employers, prepares status reports, and sometimes evaluates life care plans for litigation.
- Genex classified Williams as exempt under the FLSA’s learned professional exemption; DOL regulations generally treat registered nurses as meeting the duties test for that exemption.
- Key factual features: Williams works in the field with limited direct supervision, exercises discretion and judgment in recommendations and care plans, and uses professional nursing knowledge in reports and care coordination.
- District court found Williams’ primary duty was exempt professional work (use of advanced knowledge), not merely clerical tasks, and entered judgment for Genex; the Fourth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FMCM position falls within the FLSA learned-professional exemption | Williams: role is largely clerical, nondiscretionary liaison/scribe; not professional overtime-exempt work | Genex: duties require advanced nursing knowledge, judgment, and are performed with little supervision; RN status supports exemption | Held: Exempt under learned-professional exemption; summary judgment for Genex affirmed |
| Whether Williams’ primary duty is professional (not clerical) | Williams: majority of time is nonexempt, routine tasks; templates show scribe-like work | Genex: core duties (care plans, clinical assessments, recommendations, reports) predominantly use RN skills and discretion | Held: Primary duty is professional; use of advanced knowledge and discretion shown; templated reports do not convert role to clerical |
| Whether time-spent >50% is required to satisfy primary-duty test | Williams: she spends <50% on exempt duties so exemption fails | Genex: time is not dispositive; other factors (importance, discretion, supervision) support exemption | Held: Time is a guide but not dispositive; Williams met primary-duty requirement despite time argument |
| Burden/standard for summary judgment and exemption proof | Williams: factual disputes preclude summary judgment | Genex: undisputed record establishes exemption as matter of law; employer met burden | Held: On de novo review, employer carried burden by clear and convincing evidence; summary judgment appropriate |
Key Cases Cited
- Barrentine v. Arkansas-Best Freight Sys., Inc., 450 U.S. 728 (FLSA protects workers from substandard wages and oppressive hours)
- Arnold v. Ben Kanowsky, Inc., 361 U.S. 388 (FLSA exemptions construed narrowly against employers)
- Icicle Seafoods, Inc. v. Worthington, 475 U.S. 709 (distinguishing factual questions of time spent from legal question of exemption applicability)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment requires concrete evidence for nonmoving party)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment when nonmoving party cannot meet burden on essential element)
- Shockley v. City of Newport News, 997 F.2d 18 (employer must prove exemption by clear and convincing evidence)
- Darveau v. Detecon, Inc., 515 F.3d 334 (high compensation is indicator of exempt status)
- Walton v. Greenbrier Ford, Inc., 370 F.3d 446 (determination of FLSA exemption is legal question informed by facts)
- Henry v. Purnell, 652 F.3d 524 (standard of appellate review for summary judgment)