Joseph E. Martin v. Armstrong Transfer & Storage Co., Inc./Armstrong Relocation Company

Summary

The court denied Armstrong Transfer & Storage Co., Inc.’s motion to dismiss Joseph E. Martin’s Fair Labor Standards Act overtime claim. The court held that the complaint did not establish an FLSA exemption on its face and plausibly alleged that Martin worked more than 40 hours per week without receiving required overtime compensation.

Holdings

1. Dismissal based on Martin's alleged salaried, exempt status was improper because FLSA statutory exemptions are affirmative defenses borne by the employer, and the complaint did not admit all elements of an exemption.
2. Martin plausibly stated an FLSA overtime claim by alleging that he worked more than forty hours per week, was not paid overtime or time-and-a-half for those hours, worked for an employer engaged in commerce, and was owed approximately $70,000; the complaint was not required to identify particular workweeks, dates, or exact overtime hours.

Questions Presented

1. Whether the complaint could be dismissed at the pleading stage based on Armstrong's assertion that Martin was a salaried, exempt employee.
2. Whether Martin plausibly alleged a claim for unpaid overtime under the FLSA without identifying specific workweeks, dates, or numbers of overtime hours.

Disposition

dismissed