Ramos v. Baldor Specialty Foods, Inc.
687 F.3d 554
| 2d Cir. | 2012Background
- Plaintiffs are night-shift captains in Baldor’s Warehouse Department seeking unpaid overtime, liquidated damages, and attorneys’ fees under the FLSA and NYLL.
- District Court granted summary judgment for Baldor, holding captains fall within the FLSA executive exemption.
- The only disputed criterion was whether the captains supervise a customarily recognized department or subdivision with permanent status and function.
- Captains supervise teams of 3–6 pickers, with authority to direct work, assign tasks, and influence performance and promotions.
- Teams have distinct assigned work areas, regular reporting structures, and continuous operation within Baldor’s Night Warehouse Department since at least 1999; captains meet other executive-exemption criteria (salary, primary duty, directing two or more employees, and weight given to hiring/firing recommendations).
- Court affirmed the district court’s summary judgment, holding captains are executives under 29 C.F.R. § 541.100(a) and § 541.103.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether captains supervise customarily recognized departments/subdivisions. | Teams are not distinct units; interchangeable and identical in function. | Teams are customarily recognized subdivisions with permanent status and function. | Yes; teams are customarily recognized subdivisions with continuing function. |
| Whether captains’ primary duty is management of a department/subdivision. | Primary duty is not clearly managerial. | Primary duty is supervising teams and managing performance. | Yes, primary duty is managing the teams. |
| Whether captains meet all four regulatory criteria for the executive exemption (salary, primary duty, directs two or more employees, weight on hiring/firing actions). | May dispute one criterion (customarily recognized subdivision). | All four criteria satisfied. | All criteria satisfied; exemption applies. |
Key Cases Cited
- Icicle Seafoods, Inc. v. Worthington, 475 U.S. 709 (U.S. 1986) (regulatory interpretation and exemptions analyzed under de novo standard)
- Long Island Care at Home, Ltd. v. Coke, 551 U.S. 158 (U.S. 2007) (agency interpretations defer to regulations when ambiguous; exemptions circumscribed)
- Martin v. Hertz Corp., 624 F.3d 537 (2d Cir. 2010) (exemption narrowly construed; burden on employer to prove executive status)
- A.H. Phillips, Inc. v. Walling, 324 U.S. 490 (U.S. 1945) (establishes framework for exemptions and regression toward narrow construction)
- West v. Anne Arundel County, 137 F.3d 752 (4th Cir. 1998) (recognizes shifts/units can qualify as subdivisions under exemptions)