Verdicts

Exemption from Overtime As a Professional Requires Specialized Education

In Young v. Cooper Cameron Corp., 08-5847-cv (2nd Cir., Nov. 12, 2009), the plaintiff worked for three years as a Product Design Specialist II (PDS II) for the defendant company. When hired, he had some 20 years of engineering-type experience and his work involved complicated technical expertise and responsibility. Like all other PDS IIs, plaintiff lacked formal education beyond a high school diploma. Plaintiff was not paid overtime because defendant had classified PDS IIs as exempt professionals under the Fair Labor Standards Act (FLSA).

After losing his job in 2004 due to a reduction-in-force, plaintiff sued the defendant under the FLSA, alleging his classification as an exempt professional willfully violated the FLSA. The district court granted summary judgment for the plaintiff on the ground that he was not an exempt professional. It found the defendant's violation of the FLSA willful. The circuit court affirmed, concluding that the plaintiff is not an exempt professional and that the defendant willfully violated the FLSA. The issue was whether a position can be exempt, notwithstanding the lack of an education requirement, if duties actually performed require knowledge of an advanced type in a field of science learning. The circuit court held that an employee is not an exempt professional unless his work requires knowledge that is customarily acquired after a prolonged course of specialized, intellectual instruction and study.