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Morgan v. Family Dollar Stores
United States Court of Appeals for the Eleventh Circuit
551 F.3d 1233 (2008)
Janice Morgan (plaintiff) represented an opt-in class of 1,424 store managers in a collective action for unpaid overtime against Family Dollar Stores, Inc. (Family Dollar) (defendant). Family Dollar operated more than 6,000 discount stores in 40 states and the District of Columbia. Family Dollar’s organizational structure included 380 districts, each overseen by a district manager. Each district manager supervised the operations of 10 to 30 stores. Family Dollar supplied instruction manuals to each store. The manuals contained operating policies that covered in minute detail how the store would be run. Almost all operational decisions not covered in the manuals were vested in the district managers. The evidence at trial showed that the store managers spent 80 to 90 percent of their time on nonexempt manual labor, such as stocking shelves, running cash registers, unloading trucks, and cleaning. Family Dollar considered these manual tasks to be essential to the store-manager role due to each store’s limited payroll budget and the amount of labor required to run the store. Family Dollar argued that the managers, who routinely worked 60 to 70 hours per week and did not receive overtime compensation, were employed in an executive capacity and, therefore, exempt from the overtime requirements of the Fair Labor Standards Act (FLSA). The jury found that the managers were not exempt executives and awarded them overtime wages and liquidated damages. Family Dollar appealed.
Rule of Law
Holding and Reasoning (Hull, J.)
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