Specht, et al v. The City of Sioux Fall, No. 10-1733 (8th Cir. 2011)
Annotate this CaseAppellant, a firefighter for the City of Sioux Fall's ("City") Fire Rescue Department ("SFFR") and 15 other SFFR firefighters, filed suit against the City seeking overtime compensation under the Fair Labor Standards Act ("FLSA"), 29 U.S.C. 207(p)(1), for work performed at the request of the State of South Dakota ("State") to help fight wildfires in western South Dakota and Nebraska. At issue was whether the district court properly granted summary judgment to the City, finding that the special detail exemption of the FLSA applied because the City firefighters volunteered for the State firefighting assignment and that the State and City were separate and independent employers and therefore, the hours the firefighters worked for the State were not combined with the hours worked for the City for purposes of overtime compensation. The court held that the section 207(p)(1) prong of voluntariness was satisfied where the firefighters have failed to present evidence that those of them who said "no" to the deployment were punished or reprimanded in any way and the firefighters who rejected deployment did so in spite of their refusal causing them to move down on the overtime list. The court also held that the record could be viewed to establish that the City, not the State, was the firefighter's employer during their deployment. Therefore, the court reversed summary judgment and remanded because genuine issues of fact existed as to which entity the firefighters were actually employed by.
Court Description: Civil case - Fair Labor Standards Act. The district court erred in finding that the special detail exemption of the Fair Labor Standards Act applied to the plaintiff firefighters' claims for overtime compensation for work performed for the State of South Dakota as there was a genuine issue of material fact whether the City was the firefighters' employer during their deployment to fight wildfires.
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