Williams v. Enterprise Resource Planning International, LLC

Summary

The United States District Court for the Southern District of California denied defendants’ motion to dismiss a Fair Labor Standards Act overtime claim. The court held that, under the Service Contract Act, fringe-benefit payments are excluded from the FLSA regular rate only to the extent they are excluded under FLSA § 207(e), and that defendants had not shown that the health and wellness payments qualified for exclusion. The court concluded that cash payments to employees in lieu of health benefits were not excluded under the applicable statutory language.

Holdings

1. Section 6707(e) excludes SCA fringe-benefit payments from the FLSA regular rate only to the extent that the payments are excluded under FLSA § 207(e). Because the disputed health and wellness payments were not shown to fall within a § 207(e) exclusion, defendants did not establish that the payments were exempt from the regular rate.
2. The First Amended Complaint plausibly stated a claim for unpaid FLSA overtime, and defendants' motion to dismiss was denied.

Questions Presented

1. Whether the Service Contract Act, 41 U.S.C. § 6707(e), excludes health and wellness or cash-in-lieu-of-benefits payments from the FLSA regular rate of pay when those payments are not excluded under 29 U.S.C. § 207(e).
2. Whether the First Amended Complaint plausibly stated an FLSA claim for unpaid overtime.

Disposition

other