Buntin v. Schlumberger Technology CorporationAnnotate this Case
A federal district court certified two questions of law to the Alaska Supreme Court. Schlumberger Technology Corporation was a Texas corporation providing technology services to the oil and gas industry in Alaska. Travis Buntin worked for Schlumberger in Alaska until early 2016. Shortly thereafter Buntin sued Schlumberger in federal court alleging, among other things, failure to pay overtime compensation in violation of the Alaska Wage and Hour Act (AWHA). Schlumberger responded that Buntin was not entitled to overtime compensation because the AWHA exempts individuals employed “in a bona fide executive, administrative, or professional capacity” from overtime payment. Responding to the federal court's questions, the Alaska Supreme Court concluded that an employer had to prove that an AWHA exemption applied by a preponderance of the evidence, and reversed precedent to the contrary. The Supreme Court also concluded that the interpretive principle in Encino Motorcars v. Navarro, 138 S. Ct. 1134 (2018) that courts must give federal Fair Labor Standards Act (FLSA) exemptions a fair interpretation applied when the AWHA text explicitly requires alignment with FLSA interpretations.