Jones v. New Orleans Regional Physician Hospital Organization, Inc., No. 19-31027 (5th Cir. 2020)Annotate this Case
The Fifth Circuit affirmed the district court's grant of summary judgment in favor of Peoples Health Network in an action brought by former employees, alleging violations of the Fair Labor Standards Act (FLSA). The district court concluded that the employees' job duties fall within the administrative employee exemption to the statute.
The court agreed and concluded de novo that the evidence created no genuine issue of material fact and the district court had ample support from the record to conclude that plaintiffs were salaried employees; plaintiffs' primary job duties directly relate to the management or general business operations of Peoples Health or its customers; and plaintiffs' primary job duties included the exercise of discretion and independent judgment with respect to matters of significance. The court also concluded that the district court applied the correct standard of review, and the district court made clear in its conclusion that it was applying the summary judgment standard to Peoples Health's burden of proving the administrative exemption by a preponderance of the evidence.