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Northern District of Illinois Finds That Director of Golf Operations Exempt, Cannot Receive Overtime in Hall v. Sterling Park District

The Fair Labor Standards Act (FLSA) allows employees who are paid an hourly wage to be paid “time and a half,” or 1.5 times their hourly wage, for every hour worked over eight in a day, or 40 in a week. While this sounds good, not every employee is an hourly worker — instead, many employees fall into one of the FLSA “exemptions.” The FLSA does not provide overtime compensation for “exempt” employees whose work is “executive,” “administrative,” or “professional” in character. The FLSA lists the criteria that an employee must meet to be exempt. This criteria considers the salary level ($23,600 and above is exempt) and the types of duties the employee performs. For instance, an “executive” employee might plan the work and hire other employees; an “administrative” employee may do office work related to general business operations; and a professional has specialized education and skills (like a lawyer or physician). If you live in Illinois and feel you have been denied overtime pay, contact an Illinois overtime attorney to find out whether you meet an exemption.

In Hall v. Sterling Park District, the plaintiff, Phillip Hall, sued the defendant for violating the FLSA, the Illinois Minimum Wage Law, and the Illinois Wage Payment Collection Act. He claimed that the defendant denied him unpaid overtime and unused vacation time. The defendant countered that Hall was an “exempt” employee and therefore could not receive overtime pay.

Hall was hired as the Director of Golf Operations at the defendant’s Emerald Hill Golf and Learning Center. He spent the next 12 years working there, until terminated at the age of 53. His position involved overseeing the golf course, clubhouse, shop, and banquet facilities. Hall described his duties as being 25% managerial, 75% manual. He spent much of his time improving the poor condition of the course, which involved manual labor. At the same time, he allegedly made recommendations about hiring, discipline, and salary of part-time employees. Hall described these duties as little more than routine paperwork. Overall, he claimed he worked more than 40 hours every week. He finally filed suit after his contract was not renewed, and he was replaced in his position by a 22-year old.

Judge Michael Mahoney of the Northern District of Illinois sided with the defendant on the exemption issue. The FLSA describes an executive employee as one (1) who earns more than $455 per week, (2) whose primary duty is “management of the enterprise” where he is employed, (3) who “customarily directs” the work of at least two employees, and (4) who has the authority to hire and fire. The judge found that despite Hall’s claims, he met all of these standards. He disagreed with the plaintiff that his duties were primarily manual labor; while some manual labor was involved, most of Hall’s duties consisted of supervising several different employees (golf pro, assistant superintendent), budgeting and marketing, and making other decisions that affected the golf facility. Hall therefore met the standard of an executive employee and was exempt from receiving overtime. However, Judge Mahoney felt that his vacation and age discrimination claims had enough merit that he could continue to pursue them in court.

The attorneys at Chicago Overtime Law Center have decades of experience litigating wage and hour cases, including overtime, meal breaks, vacation pay, and tips. We have offices conveniently located in Oakbrook Terrace and Chicago, Illinois. Contact an Elgin wage and hour attorney at the Chicago Overtime Law Center today at 312-869-4095.