Cunningham v. Circle 8 Crane Services, No. 22-50170 (5th Cir. 2023)
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Plaintiff was employed by Defendant for three years between 2017 and 2020. Initially, he was paid hourly and received overtime compensation, but in March 2018, despite no change in job responsibilities, Defendant converted him to a salaried position. In March 2020, Plaintiff gave his two-week notice to Defendant that he would be resigning. Three days later, Defendant terminated him.
Plaintiff sued, claiming that Defendant failed to pay him overtime compensation in violation of the FLSA, 29 U.S.C. Sec. 207(a). Defendant sought summary judgment, claiming Plaintiff was exempt from overtime compensation requirements under the Motor Carrier Act exemption as a “mechanic.” The district court agreed, granting summary judgment in Defendant's favor. Plaintiff appealed.
Generally, the FLSA requires an employer to pay overtime compensation to any employee working more than forty hours in a workweek. However, as relevant here, under the MCA exemption, the overtime compensation requirement does not apply if “the Secretary of Transportation has [the] power to establish qualifications and maximum hours of service” for the employee. The Fifth Circuit affirmed, finding that the Motor Carrier Act exemption applied due to Plaintiff's position as a mechanic.
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