New York Product Design Specialist Entitled to Overtime
The Second Circuit decided Young v. Cooper Cameron on November 12, 2009. Andrew Young designed hydraulic power units for oil rigs. Young, like most of the other product designers at his company, never went to college. Instead, Young acquired expertise over his twenty year career in various engineering positions. His job required a fair amount of skill as he designed complicated pieces of equipment. Young’s employer, Cooper Cameron Corporation, categorized him as an exempt professional under the Fair Labor Standards Act and paid him a salary with no overtime.
Under the Fair Labor Standards Act, employees who are deemed “professional” are exempt from the overtime pay rules. Young challenged Cooper Cameron claiming that he was entitled to overtime pay because he was misclassified as a professional under the FSLA. The District Court agreed and found that Cameron Cooper misclassified Young and that Young was entitled to overtime pay. The Second Circuit agreed.
In order to qualify as an exempt professional under the FSLA, the position in question must customarily require an advanced academic degree. The regulations state that a professional is someone “[w]hose primary duty consists of the performance of [w]ork requiring knowledge of an advance type in a field of science or learning customarily acquired by a prolonged course of specialized intellectual instruction and study.” 29 C.F.R. § 541.3(a). Labels such as “engineer” and the like are not persuasive as the court noted that there are many engineers who do not hold advanced degrees.
In this case, none of the product design specialists employed by Cameron Cooper had advanced degrees. They were all high school graduates with no college training. Since the work of a product design specialist at Cooper Cameron did not customarily require a prolonged course of specialized intellectual study, the Court held that Young was misclassified as a professional and therefore entitled to overtime pay.
