Ryan Henry v. Quicken Loans, Inc.
698 F.3d 897
| 6th Cir. | 2012Background
- Mortgage bankers like Henry sued Quicken Loans claiming overtime wages were owed under the FLSA for 2003–2007.
- Quicken contends mortgage bankers fall within the administrative exemption for management-related, non-manual work.
- Jury trial lasted five weeks; jury found Quicken’s characterization of the bankers’ duties to be correct.
- District court denied post-trial motions and entered partial summary judgment in Quicken’s favor on some defenses.
- The court reviews whether the mortgage bankers meet the administrative exemption’s prongs: management-related duties and discretion/independent judgment.
- Record evidence showed mortgage bankers performed a range of activities including information gathering, advising clients, and loan selection, not merely selling products.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mortgage bankers satisfy the management-related prong. | Henry argues primary duties relate to managing operations. | Quicken shows duties directly related to management/general operations. | Affirmed in favor of Quicken. |
| Whether mortgage bankers satisfy the discretion and independent judgment prong. | Henry asserts discretionary judgment in client recommendations. | Quicken shows discretion and independent judgment in loan recommendations. | Affirmed in favor of Quicken. |
Key Cases Cited
- Thomas v. Speedway SuperAmerica, LLC, 506 F.3d 496 (6th Cir. 2007) (defining ‘primary duty’ and importance of fact issues in exemptions)
- Renfro v. Indiana Michigan Power Co. (Renfro II), 497 F.3d 573 (6th Cir. 2007) (discretion and supervisory factors do not negate discretion in practice)
- Renfro v. Indiana Mich. Power Co. (Renfro I), 370 F.3d 512 (6th Cir. 2004) (heavily-regulated nature does not preclude discretion)
- Schaefer v. Indiana Michigan Power Co., 358 F.3d 394 (6th Cir. 2004) (jury must weigh credibility of conflicting day-to-day duties)
- Maestas v. Day & Zimmerman, LLC, 664 F.3d 822 (10th Cir. 2012) (primary duty is a factual determination suitable for a factfinder)
- Chao v. Double JJ Resort Ranch, 375 F.3d 393 (6th Cir. 2004) (exemption inquiry is primarily a question of fact)