Veronica R. Grage v. Northern States Power Co.

Grage sued NSP for unpaid overtime under the FLSA; the district court granted Grage partial summary judgment on exemption, denying NSP summary judgment.
Grage was employed for over 30 years, promoted to Supervisor I at NSP, working at the Chestnut Service Center and salaried as exempt.
NSP described Grage’s duties as high-level planning, directing field operations, and resource allocation; Grage contends she mainly scheduled crews and had limited management discretion.
The district court held Grage did not meet the administrative exemption because her primary duty was production-related rather than management or general business operations.
On review, the Eighth Circuit reversed in part, holding questions of fact about Grage’s primary duties and discretion preclude summary judgment, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Grage’s primary duty is directly related to management or general business operations	Grage acted primarily in scheduling and dispatch with minimal management discretion	Grage’s duties directly related to NSP’s management/operations as Supervisor I	Genuine issues of material fact; remand for trial
Whether Grage’s duties involve discretion and independent judgment in matters of significance	Grage had limited discretion and largely followed designers’ work orders	Grage exercised substantial discretion in prioritizing work and planning	Genuine issues of material fact; remand for trial
Whether a job title alone determines exempt status	Supervisor title under Production Operations does not prove exemption	Job title can support exemption when duties fit § 541.201	Title alone is insufficient; factual questions remain

Reich v. Avoca Motel Corp., 82 F.3d 238 (8th Cir. 1996) (primary duty must be related to management or general business operations)
Spinden v. GS Roofing Prods. Co., 94 F.3d 421 (8th Cir. 1996) (whether activities exclude from overtime is a question of law)
Icicle Seafoods, Inc. v. Worthington, 475 U.S. 709 (1986) (test for exemptions and related duties guidance)
Renfro v. Ind. Mich. Power Co., 370 F.3d 512 (6th Cir. 2004) (administrative work may be ancillary to production)
Martin v. Cooper Elec. Supply Co., 940 F.2d 896 (3d Cir. 1991) (administrative tasks can be ancillary to production)
Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (credibility and factual questions are for the jury in exemptions cases)
Re Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (summary judgment credibility and inference are jury functions)