Gilchrist v. Schlumberger

United States Court of Appeals for the Fifth Circuit · July 14, 2025 · No. 22-50257

Summary

This Fifth Circuit opinion reverses a district court's judgment in a Fair Labor Standards Act overtime pay dispute. The court held that the plaintiffs, who worked as Measurements While Drilling Field Specialists, qualified as highly compensated employees exempt from overtime pay requirements because they customarily and regularly performed administrative duties, including quality control and advising clients on drilling operations.

Court
United States Court of Appeals for the Fifth Circuit
Writing for the Court
Jones; Richman; Ho
Jurisdiction
United States Court of Appeals for the Fifth Circuit
Decision date
July 14, 2025
Docket number
22-50257
Procedural posture
Appeal from the United States District Court for the Western District of Texas, which awarded overtime pay to the plaintiffs.
Standard of review
Legal conclusions reviewed de novo; factual findings reviewed for clear error.
Precedential value
published
Parties
Schlumberger Technology Corp. v. John Gilchrist; Byron Brockman
Disposition
reversed

Topics

flsa

Practice areas

employment law

Questions Presented

  1. Whether Gilchrist and Brockman qualify as highly compensated employees exempt from the FLSA overtime provisions based on the performance of administrative duties.

Holdings

  1. Gilchrist and Brockman qualify as highly compensated employees exempt from the FLSA overtime requirement because they regularly performed administrative duties of quality control and advisory work.

Key quotations

We hold that Gilchrist and Brockman qualify as highly compensated employees exempt from the Fair Labor Standards Act’s (FLSA’s) overtime pay requirement because they performed administrative duties. (at 1)
We therefore REVERSE and REMAND the judgment with instructions to dismiss. (at 17)

Factual background

Gilchrist and Brockman worked as Measurements While Drilling (MWD) Field Specialists for Schlumberger, performing real‑time data collection, quality‑control of survey data, and advising clients on drilling operations. They earned over $200,000 annually and were not paid overtime.

Procedural history

The district court found that Gilchrist and Brockman were not exempt under the FLSA and awarded overtime. The plaintiffs appealed, arguing they qualify as highly compensated employees performing administrative duties.

Remand instructions

Remand with instructions to dismiss the district court’s judgment.

Court Document

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