Williams-Bell v. British Standards Institution, Inc.
1:18-cv-05386
| N.D. Ill. | Mar 31, 2021Background
- Plaintiff Maria Williams-Bell was an ISO 9001 Quality Assurance Auditor (Client Manager) at BSI from Sept. 2017 to Feb. 2018; she resigned and sued under the FLSA and Illinois Minimum Wage Law seeking overtime pay.
- Her primary duty was conducting ISO 9001 certification audits of BSI’s clients (solo or as lead auditor), including planning audits, reviewing client QMS processes (excluding financial controls), interviewing employees, identifying nonconformances and opportunities for improvement, and preparing post-audit reports.
- She recommended certification decisions to BSI’s technical review committee, which made the final certification determination; she communicated with supervisors infrequently and had limited day-to-day oversight.
- Williams-Bell was salaried at roughly $1,250/week (exceeding the applicable salary threshold) and the parties agreed her primary duty was performing ISO 9001 assessments.
- BSI moved for summary judgment arguing Williams-Bell is exempt under the FLSA administrative exemption; the court evaluated the three regulatory elements (salary, work directly related to management/business operations, and exercise of discretion and independent judgment).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams-Bell’s primary duty is “directly related to management or general business operations” (administrative element) | Williams-Bell contends she is a production employee because she "produced" certifications — BSI’s core service — so her work is not administrative | BSI argues audits are ancillary to clients’ core businesses and auditing/quality control is listed in DOL examples of business-operations-related work | Court: Work is non-manual and auditing quality-management systems is directly related to clients’ management/business operations; second element satisfied |
| Whether her work involved the exercise of discretion and independent judgment with respect to matters of significance | Williams-Bell says she merely followed strict, step-by-step BSI Manual procedures and thus only “graded” conformity (no independent judgment) | BSI points to evidence she planned audits, selected processes/people to sample, assessed conformity, approved or rejected corrective action plans, and worked with little direct supervision | Court: Although guided by a manual, her tasks required evaluating options, using professional judgment before/during/after audits, and were more than mechanical application; third element satisfied |
| Whether salary threshold for administrative exemption is met | N/A — Williams-Bell does not dispute | N/A — BSI shows salary exceeds the legal minimum | Court: Salary requirement met (was well above threshold) |
| Whether IMWL claim survives if FLSA claim fails | Williams-Bell argues separate state-law relief | BSI argues IMWL depends on FLSA violation | Court: IMWL claim contingent on FLSA; because administrative exemption applies, IMWL claim fails and collective-certification motion is moot |
Key Cases Cited
- Schaefer–LaRose v. Eli Lilly & Co., 679 F.3d 560 (7th Cir. 2012) (calls for fact-intensive analysis of duties under the exemptions)
- Bigger v. Facebook, Inc., 947 F.3d 1043 (7th Cir. 2020) (administrative exemptions must satisfy all regulatory criteria and be read fairly)
- Encino Motorcars, LLC v. Navarro, 138 S. Ct. 1134 (2018) (exemptions are to be given a fair — not narrow — reading)
- Roe‑Midgett v. CC Servs., Inc., 512 F.3d 865 (7th Cir. 2008) (claims adjusters/auditing work can be administrative when ancillary to clients’ business operations)
- Kennedy v. Commonwealth Edison Co., 410 F.3d 365 (7th Cir. 2005) (state-law wage claims parallel FLSA analysis)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard)