Court Rules Travel Plaza Operator Properly Classified Employee as Overtime-Exempt Manager

In a recent legal battle, travel plaza operator HMSHost emerged victorious as the 6th U.S. Circuit Court of Appeals upheld its classification of a former district director of operations as an overtime-exempt employee under the Fair Labor Standards Act (FLSA). This ruling, made in the case of Manteuffel v. HMS Host Tollroads, Inc., sheds light on the requirements for the executive exemption and the criteria used to determine an employee’s primary duty.

Background

HMSHost had classified the district director as both an executive and administrative employee. However, the employee disputed that he met the FLSA’s definition of an executive. This dispute led to a legal battle that ultimately ended with summary judgment being granted to HMSHost by the district court.

Summary Judgment Affirmed

The 6th Circuit upheld the district court’s ruling, affirming that the management duties performed by the employee were indeed his primary duty. The court highlighted that even though the employee spent a significant portion of his time on nonexempt work, the importance of his management duties to the overall success of the company outweighed this factor.

Criteria for Executive Exemption

To be exempt from FLSA’s overtime requirements, employees must perform specific job duties. For executive employees, the primary duty must involve the management of the enterprise or a customarily recognized department or subdivision thereof. This primary duty requirement is crucial in determining an employee’s eligibility for the executive exemption.

Primary Duty of Management

While the FLSA’s regulations recognize that the amount of time an employee spends performing exempt work can be a guide, it emphasizes that time alone is not the sole determinant of an employee’s primary duty. The 6th Circuit echoed this sentiment, stating that the FLSA does not require exempt employees to spend more than 50% of their time on exempt work. Instead, a holistic evaluation of an employee’s job responsibilities and the impact of their management duties are essential.

Factors Supporting Management Duties

The 6th Circuit considered various factors in its analysis that supported the employee’s primary duty being management. Firstly, the court emphasized that the employee’s management duties were of greater importance to the company’s overall success than any nonexempt work he performed. The employee’s ability to operate free from direct oversight and relatively free from supervision also indicated a management role. Additionally, the court noted a significant salary disparity, with the employee earning an annual salary of $75,000 compared to nonexempt frontline employees earning $10 per hour, further emphasizing his managerial status.

Compensation Disparity

The substantial difference in compensation between the exempt employee and nonexempt employees was a significant consideration for the court. This disparity in compensation supported the conclusion that the primary duty of the exempt employee was management. The higher salary indicated that the employee’s role was more aligned with the management and direction of the company, rather than routine nonexempt tasks.

The ruling in Manteuffel v. HMS Host Tollroads, Inc. reaffirms the importance of evaluating an employee’s primary duty when determining their eligibility for overtime exemption under the FLSA. The court’s focus on factors such as the significance of management duties, level of supervision, and compensation disparity provides valuable guidance for employers in correctly classifying employees. By thoroughly analyzing an employee’s job responsibilities, companies can ensure compliance with the FLSA and avoid potential legal disputes surrounding overtime-exempt status.

Explore more

How AI Agents Work: Types, Uses, Vendors, and Future

From Scripted Bots to Autonomous Coworkers: Why AI Agents Matter Now Everyday workflows are quietly shifting from predictable point-and-click forms into fluid conversations with software that listens, reasons, and takes action across tools without being micromanaged at every step. The momentum behind this change did not arise overnight; organizations spent years automating tasks inside rigid templates only to find that

AI Coding Agents – Review

A Surge Meets Old Lessons Executives promised dazzling efficiency and cost savings by letting AI write most of the code while humans merely supervise, but the past months told a sharper story about speed without discipline turning routine mistakes into outages, leaks, and public postmortems that no board wants to read. Enthusiasm did not vanish; it matured. The technology accelerated

Open Loop Transit Payments – Review

A Fare Without Friction Millions of riders today expect to tap a bank card or phone at a gate, glide through in under half a second, and trust that the system will sort out the best fare later without standing in line for a special card. That expectation sits at the heart of Mastercard’s enhanced open-loop transit solution, which replaces

OVHcloud Unveils 3-AZ Berlin Region for Sovereign EU Cloud

A Launch That Raised The Stakes Under the TV tower’s gaze, a new cloud region stitched across Berlin quietly went live with three availability zones spaced by dozens of kilometers, each with its own power, cooling, and networking, and it recalibrated how European institutions plan for resilience and control. The design read like a utility blueprint rather than a tech

Can the Energy Transition Keep Pace With the AI Boom?

Introduction Power bills are rising even as cleaner energy gains ground because AI’s electricity hunger is rewriting the grid’s playbook and compressing timelines once thought generous. The collision of surging digital demand, sharpened corporate strategy, and evolving policy has turned the energy transition from a marathon into a series of sprints. Data centers, crypto mines, and electrifying freight now press