Dewan v. M-I, L.L.C., doing business as M-I SWACO

858 F.3d 331 (2017)

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Dewan v. M-I, L.L.C., doing business as M-I SWACO

United States Court of Appeals for the Fifth Circuit
858 F.3d 331 (2017)

Facts

Matthew Dewan and William Casey (plaintiffs) were employed as drilling-fluid specialists for M-I, L.L.C. (defendant), d/b/a M-I SWACO. M-I SWACO designed drilling-fluid systems and provided services that improved drilling performance for companies that drilled for gas and oil. Dewan and Casey were paid more than $455 per week. Dewan’s and Casey’s duties entailed ensuring the fluid used in drilling on a particular customer’s oil field maintained the properties laid out in the mud plan developed by M-I SWACO’s engineers. Dewan and Casey monitored customers’ wells onsite, tested the drilling mud, and made recommendations to their superiors. Neither Dewan nor Casey had the authority to use their own discretion to alter the mud plan. Dewan and Casey sued M-I SWACO for overtime wages. M-I SWACO sought summary judgment and raised an affirmative defense that the administrative exemption of the Fair Labor Standard Act (FLSA) applied to Dewan and Casey. Application of the administrative exemption required (1) that an employee’s compensation was at least $455 per week, (2) the employee’s primary duty was related directly to managing the employer’s or its customers’ overall company operations, and (3) the employee had authorization to exercise independence and discretion in important matters. A trial court agreed with M-I SWACO, finding that Dewan’s and Casey’s work was not manual and was related directly to M-I SWACO’s or its customers’ overall company operations and that Dewan and Casey exercised discretion in matters of importance. The trial court granted summary judgment for M-I SWACO. Dewan and Casey appealed, arguing that the trial court erred because their work was more akin to manual labor and was not related to the administrative work associated with M-I SWACO’s overall management. Furthermore, Dewan and Casey testified that they had to seek approval for any necessary changes to a customer’s mud plan. Dewan and Casey averred that with regard to the second and third elements of the FLSA’s administrative exemption, genuine issues of material fact existed.

Rule of Law

Issue

Holding and Reasoning (Southwick, J.)

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