Walsh v. Unitil Service Corp., No. 22-1070 (1st Cir. 2023)
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The First Circuit vacated the judgment of the district court granting summary judgment in favor of Unitil Service Corporation and dismissing the complaint brought by the Department of Labor (DOL) seeking overtime compensation under the Fair Labor Standards Act's (FLSA) for hours worked in excess of forty hours per week for dispatchers and controllers (collectively, Employees) employed by Unitil, holding that the district court erred.
In entering its judgment, the district court concluded that Employees were administrative, exempt from the FLSA, and thus not entitled to overtime pay because their "primary duty" was "directly related" to the general business operations of Unitil Service's customers. On appeal, Unitil argued that Employees were exempt administrative employees under federal law and, as such, were not entitled to overtime payments. The First Circuit vacated the judgment below, holding that the district court improperly did not apply a "relational" analysis comparing the business purpose of Unitil and/or its customers to the primary duty of Employees.
The court issued a subsequent related opinion or order on January 30, 2023.
The court issued a subsequent related opinion or order on March 22, 2023.
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