Rejecting a challenge to classification as an exempt supervisor in a warehouse setting District Court Judge James C. Turk of the Western District of Virginia ruled last week that a “personnel supervisor” in a tire production plant qualified for the FLSA’s executive exemption because “the vast majority of his time was spent in management-type functions” and his input into personnel decisions was “given sufficient weight.”  Martin v. Yokohama Tire Corp., 2013 U.S. Dist. LEXIS 161228 (W.D. Va. Nov. 12, 2013).

In Martin, Plaintiff’s general work duties included directing the work of all hourly employees within his division and shift, typically seven to ten employees.  Plaintiff was accountable for production and quality and ensured that all equipment was operating properly.  He dealt with any problems that arose with operations and provided continuous reports to his supervisors regarding production numbers.  Additionally, Plaintiff oversaw the training of new employees on how to operate machines and ran monthly safety drill for his employees.  The Court, in holding that Defendant properly classified Plaintiff as an exempt employee, relied on the fact that a majority of his time was spent in management-type functions, and noted that other employees, especially Union witnesses, all testified that he was a supervisor and a member of management.

Rejecting Plaintiff’s assertion that “he ‘didn’t get [any] say-so’” because his performance evaluations and recommendations were not always followed, the Court held that “his opinions were (at least occasionally) given sufficient weight.”  The other requirements for the executive exemption, including salary basis compliance and directing the work of other employees, were not subjects of dispute.

Martin is a favorable decision for employers within Virginia and the Fourth Circuit, demonstrating a court’s practical, reasonable approach to interpretation of the FLSA’s executive exemption.  Employers should regularly review their classification of individuals as exempt status based on federal decisions within the relevant Circuit and, as applicable, state law.