William Christopher Mathis, as Administrator of the Estate of Michael Jerrime Mathis v. Jonathan Stewart, d/b/a Stewart Roofing

Summary

The court denied William Christopher Mathis’s motion for summary judgment in an FLSA overtime action brought on behalf of the Estate of Michael Jerrime Mathis. Applying the economic-reality test, the court held that the evidence could permit a reasonable factfinder to conclude that Michael Mathis was an independent contractor rather than an employee. The court also alternatively considered whether the evidence established uncompensated overtime work.

Holdings

1. Plaintiff failed to establish as a matter of law that Michael Mathis was Stewart's employee. Viewing disputed evidence in Stewart's favor, a reasonable factfinder could find that Mathis was an independent contractor.
2. Plaintiff failed to meet his summary-judgment burden to show that Michael Mathis worked uncompensated overtime. General estimates that Mathis worked five or six days per week and ten to twelve hours per day, without identifying particular weeks, job sites, job durations, or work performed, were insufficient to support a reasonable inference of overtime.
3. Plaintiff was not entitled to summary judgment on liquidated damages or willfulness because those forms of relief presupposed a finding that Stewart violated the FLSA, which plaintiff had not established.

Questions Presented

1. Whether the evidence established as a matter of law that Michael Mathis was an employee rather than an independent contractor under the FLSA's economic-reality test.
2. Whether the evidence established as a matter of law that Michael Mathis worked uncompensated overtime.
3. Whether the plaintiff was entitled to liquidated damages or a three-year statute of limitations based on alleged willfulness.

Disposition

other