Recent Development by Joseph A. White
The San Antonio Independent School District (SAISD) refused to pay its nine high school athletic trainers overtime wages, even though the trainers typically worked sixty hours per week. Eight of the trainers sued the SAISD for unpaid overtime wages and liquidated damages under the Fair Labor Standards Act (FLSA). The SAISD contended that the trainers were exempt from the FLSA's overtime provision because they were employed in “professional” or “administrative” capacities. Both parties moved for summary judgment on the issue of the FLSA exemption. The United States District Court for the Western District of Texas granted the trainers' motion in part and granted SAISD's motion in part. It held that seven of the trainers were entitled to overtime wages because their employment did not meet the FLSA's “learned professional” exemption. However, the court also denied the trainers' liquidated damages claim because “SAISD had a good faith and reasonable belief that the trainers were exempt” from FLSA coverage. In addition, the court held that one of the trainers “was employed in an administrative capacity exempt from the provisions of the FLSA.” Both the trainers and the SAISD appealed. The United States Court of Appeals for the Fifth Circuit reversed the partial summary judgment for the plaintiffs and held that the SAISD's trainers were “learned professionals” exempt from the overtime provisions of the FLSA. Owsley v. San Antonio Independent School District, 187 F.3d 521, 522-23 (5th Cir. 1999).
About the Author
Joseph A. White.
Citation
75 Tul. L. Rev. 837 (2001)