Ransom, et al. v. M. Patel Enterprises, Inc., et al., No. 12-50534 (5th Cir. 2013)Annotate this Case
Plaintiffs became eligible for an award of overtime wages after a jury found plaintiffs, executive managers of Party City, were misclassified by their employer as exempt under the the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. At issue on appeal was how much overtime pay Party City owed to its employees under the FLSA. The court held that the record evidence clearly showed that plaintiffs were paid a fixed weekly salary and were expected to work fluctuating weekly hours. Therefore, the district court's 55-hour method of calculating unpaid overtime damages was error, because it miscomprehended the employment arrangement and utilized a divisor of 55 in calculating plaintiffs' regular rate of pay rather than applying a divisor equal to the number of hours actually worked in such workweek. Accordingly, the court reversed the erroneous amount of damages awarded and vacated the amount of actual damages, remanding for recalculation. The court also vacated the award of liquidated damages and the amount of attorneys' fee award, remanding for reconsideration.