Williams v. Central Transport International, Inc.
830 F.3d 773
| 8th Cir. | 2016Background
- Plaintiff Glenn Williams worked as a "switcher" at Central Transport's St. Louis terminal (Oct 2012–May 2013), performing loading/unloading, moving trailers, and forklift repositioning.
- He regularly loaded both "line-haul" (interstate) and "city" (local, including nearby Illinois) trailers; Central submitted uncontested evidence he loaded 3,827 pieces onto line-haul trailers during the period.
- Williams received on-the-job training, performed many loads by himself, and learned/used techniques to balance, secure, and stack freight, including hazardous materials.
- Williams sued under the FLSA claiming unpaid overtime; Central Transport invoked the Motor Carrier Act (MCA) exemption (29 U.S.C. § 213(b)(1)), and the district court granted summary judgment for Central.
- The legal question is whether Williams’s duties fall within the MCA exemption (i.e., whether a substantial part of his work affected motor carrier safety), which would exempt Central from FLSA overtime obligations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the MCA Exemption apply to Williams? | Williams argues he is not an exempt "loader" because he lacked responsibility for exercising judgment/discretion in building balanced loads. | Central argues Williams spent a substantial part of his time performing safety-affecting loading for interstate trailers, placing him within the MCA Exemption. | Held: Exemption applies — Williams spent a substantial part of his time loading interstate trailers, so MCA jurisdiction covers him. |
| Is DOL regulation (29 C.F.R. § 782.5(a)) defining "loader" controlling? | Williams relies on the DOL regulation requiring responsibility for judgment/discretion. | Central contends DOL regs cannot define the MCA exemption; Supreme Court precedent controls. | Held: DOL regulation is not controlling and conflicts with Supreme Court precedent; courts apply MCA/ICC standards, not DOL regs. |
| Does supervision or limited experience defeat exempt status? | Williams suggests close supervision/limited expertise show he lacked independent loader authority. | Central points to actual performance of safety-related loading tasks even if supervised or trained. | Held: Even with supervision and training, performing substantial, safety-related loading suffices for exemption. |
| Are occasional loading tasks enough for exemption? | Implicitly: if loading is trivial/occasional, exemption shouldn't apply. | Central: Williams’ loading was frequent and substantial, not de minimis. | Held: Not de minimis — substantial, routine loading of interstate trailers triggers the exemption. |
Key Cases Cited
- United States v. American Trucking Ass’ns, 310 U.S. 534 (1940) (MCA jurisdiction limited to employees whose activities affect safety of motor carrier operation)
- Southland Gasoline Co. v. Bayley, 319 U.S. 44 (1943) (MCA exemption applies where Secretary has authority, even if not exercised)
- Levinson v. Spector Motor Serv., 330 U.S. 649 (1947) (loaders who devote a substantial part of time to safety-affecting loading fall within MCA Exemption)
- Pyramid Motor Freight Corp. v. Ispass, 330 U.S. 695 (1947) (whether particular employee falls within exempt class is a judicial question; de minimis loading may not qualify)
- Morris v. McComb, 332 U.S. 422 (1947) (MCA Exemption can apply to employees of carriers with limited interstate operations when duties affect safety)