Sands v. Town of West Yellowstone

Summary

The Montana Supreme Court considered whether on-call hours worked by emergency medical technicians for the Town of West Yellowstone constituted compensable work time under the Fair Labor Standards Act. The Court held that disputed material facts concerning the restrictions on the EMTs' personal activities, geographic limitations, scheduling, and call-out duration precluded summary judgment. It reversed the judgment for the Town and remanded for a jury trial.

Holdings

1. Whether the Sands were engaged to wait, making their on-call time compensable work time, or were waiting to be engaged, making it noncompensable, depends on the facts and circumstances of the case and was not properly resolved as a matter of law on this record.
2. Cross-motions for summary judgment do not establish the absence of genuine issues of material fact, and each motion must be evaluated independently on its own merits.

Questions Presented

1. Whether the District Court erred by determining as a matter of law that the Sands' scheduled on-call time was not compensable under the FLSA.
2. Whether disputed material facts concerning the restrictions and practical effects of the on-call requirements precluded summary judgment.

Disposition

reversed_and_remanded