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Buntin v. Schlumberger Technology Corp.

EMPLOYMENT LAW

Hannah Rogers

In Buntin v. Schlumberger Technology Corp., 487 P.3d 595 (Alaska 2021), the supreme court held that an employer is required to prove an exemption to the overtime provisions of the Alaska Wage and Hour Act (AWHA) by preponderance of the evidence and that the court must give AWHA exemptions a fair reading, rather than a narrow one. (Id. at 609). Buntin sued Schlumberger, his former employer, in federal court for failure to pay overtime compensation in violation of the AWHA. (Id. at 598). Schlumberger argued that Buntin was not entitled to overtime compensation because the AWHA exempts individuals employed in an executive, administrative, or professional capacity from the overtime payment requirement. (Id.). The federal court certified two questions for the supreme court: 1) Which standard of proof applies to exemptions to the overtime provisions of the AWHA, and 2) Whether exemptions under the AWHA should receive a narrow or fair interpretation. (Id.). The supreme court noted that the previous standard of proof for AWHA exemptions, under Dayhoff v. Temsco Helicopters, 848 P.2d 1367 (Alaska 1993), was beyond a reasonable doubt. (Buntin, 487 P.3d at 601). However, the supreme court reasoned that this standard was originally erroneous because the loss of overtime pay did not result in the deprivation of liberty or fundamental rights. (Id. at 605–06). Instead, the supreme court held that a preponderance of the evidence was the more appropriate standard for proving that an employee was exempt from the overtime provisions of the AWHA. (Id. at 609). Then, the supreme court found that AWHA exemptions were expressly linked to exemptions under the Fair Labor Standards Act (FLSA), and therefore required the same reading as FLSA exemptions. (Id.). Because the FLSA required a fair reading, the AWHA also required a fair reading as opposed to a narrow one. (Id.). Therefore, the supreme court held that an employer is required to prove that an exemption to the overtime provisions of the AWHA by a preponderance of the evidence, and the court must give AWHA exemptions a fair reading. (Id.).

Buntin v. Schlumberger Technology Corp.

EMPLOYMENT LAW

Hannah Rogers

In Buntin v. Schlumberger Technology Corp., 487 P.3d 595 (Alaska 2021), the supreme court held that an employer is required to prove an exemption to the overtime provisions of the Alaska Wage and Hour Act (AWHA) by preponderance of the evidence and that the court must give AWHA exemptions a fair reading, rather than a narrow one. (Id. at 609). Buntin sued Schlumberger, his former employer, in federal court for failure to pay overtime compensation in violation of the AWHA. (Id. at 598). Schlumberger argued that Buntin was not entitled to overtime compensation because the AWHA exempts individuals employed in an executive, administrative, or professional capacity from the overtime payment requirement. (Id.). The federal court certified two questions for the supreme court: 1) Which standard of proof applies to exemptions to the overtime provisions of the AWHA, and 2) Whether exemptions under the AWHA should receive a narrow or fair interpretation. (Id.). The supreme court noted that the previous standard of proof for AWHA exemptions, under Dayhoff v. Temsco Helicopters, 848 P.2d 1367 (Alaska 1993), was beyond a reasonable doubt. (Buntin, 487 P.3d at 601). However, the supreme court reasoned that this standard was originally erroneous because the loss of overtime pay did not result in the deprivation of liberty or fundamental rights. (Id. at 605–06). Instead, the supreme court held that a preponderance of the evidence was the more appropriate standard for proving that an employee was exempt from the overtime provisions of the AWHA. (Id. at 609). Then, the supreme court found that AWHA exemptions were expressly linked to exemptions under the Fair Labor Standards Act (FLSA), and therefore required the same reading as FLSA exemptions. (Id.). Because the FLSA required a fair reading, the AWHA also required a fair reading as opposed to a narrow one. (Id.). Therefore, the supreme court held that an employer is required to prove that an exemption to the overtime provisions of the AWHA by a preponderance of the evidence, and the court must give AWHA exemptions a fair reading. (Id.).