Dietrich v. C. H. Robinson Worldwide, Inc.

CourtDistrict Court, N.D. Illinois
DecidedAugust 9, 2021
Docket1:18-cv-04871
StatusUnknown

This text of Dietrich v. C. H. Robinson Worldwide, Inc. (Dietrich v. C. H. Robinson Worldwide, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dietrich v. C. H. Robinson Worldwide, Inc., (N.D. Ill. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

Taryn Dietrich, on behalf of herself and a ) class of all those similarly situated, ) Plaintiff, ) ) No. 18 C 4871 v. ) ) Judge Ronald A. Guzmán C.H. Robinson Worldwide, Inc., ) Defendant. )

MEMORANDUM OPINION AND ORDER For the reasons stated below, C.H. Robinson Worldwide, Inc.’s (“CHRW”) motion for partial summary judgment [201] is denied in part and granted in part. As to whether CHRW is entitled to the administrative exemption under the Fair Labor Standards Act (“FLSA”) and the Illinois Minimum Wage Law (“IMWL”), the motion is denied. With respect to Plaintiff’s individual discrimination claims, the motion is granted. The parties are directed to confer within 10 days of the date of entry of this order to discuss potential trial dates. No more than 14 days from the date of entry of this order, the parties are to submit a joint statement with three proposed trial dates in October and November 2022. The statement shall also include an estimated length for the trial.

STATEMENT

Facts The Court assumes familiarity with the facts of the case and the Court’s prior orders. CHRW, a global provider of transportation services and logistics solutions, hired Plaintiff as a Carrier Account Manager in June 2013. She was employed until June 1, 2017, when she was purportedly constructively discharged. Plaintiff alleges that CHRW failed to pay her and those similarly situated1 overtime for regularly working more than 40 hours per week, in violation of the FLSA and IMWL (Counts I and II). Plaintiff also brings the following discrimination claims: gender discrimination under Title VII (Count III); disability discrimination under the Americans with Disabilities Act (“ADA”) (Count IV); retaliation under Title VII (Count V); and retaliation under the ADA (Count VI). Additional facts will be discussed as necessary in the Analysis section of this order.

CHRW moves for partial summary judgment on the FLSA and IMWL counts, contending that Plaintiff and those similarly situated were properly classified as administratively

1 These individuals include Carrier Account Managers, Capacity Account Managers, Capacity Key Account Managers (collectively “CAMs”), and Senior Carrier Account Managers (“SCAMs”), who are referred to collectively as Carrier Managers (“CMs”). exempt from the statutes’ overtime requirements. CHRW also moves for summary judgment on Plaintiff’s individual discrimination claims.

Standard Summary judgment is proper where “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); see also Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986). A genuine dispute as to any material fact exists if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The Court “consider[s] all of the evidence in the record in the light most favorable to the non-moving party, and . . . draw[s] all reasonable inferences from that evidence in favor of the party opposing summary judgment.” Skiba v. Ill. Cent. R.R., 884 F.3d 708, 717 (7th Cir. 2018) (internal citation and quotations omitted).

Analysis A. FLSA and IMWL2 The FLSA exempts from its overtime-pay requirement those employed in an “administrative . . . capacity.” 29 U.S.C. § 213(a)(1). The regulations set forth a three-part test for determining whether an employee falls under the administrative exemption. First, the employee must be compensated on a salary basis at a rate of not less than $455.00 per week. 29 C.F.R. § 541.200(a)(1). Second, the employee’s primary duty must be the performance of office or non-manual work “directly related to the management or general business operations of the employer or the employer’s customers.” 29 C.F.R. § 541.200(a)(2). Finally, the employee’s primary duty must include the exercise of discretion and independent judgment with respect to matters of significance. 29 C.F.R. § 541.200(a)(3). CHRW argues that Plaintiff3 meets these elements and thus qualifies for the administrative exemption.

As to the first element—rate of compensation—Plaintiff does not dispute that CHRW has satisfied it; thus, the Court considers this issue resolved. With respect to the second element, Plaintiff contends that genuine issues of material fact exist as to whether the relevant employees’ primary duty was the “performance of work directly related to the management or general business operations of the employer or the employer’s customers.” 29 C.F.R. § 541.201. An employee’s primary duty is the “principal, main, major or most important duty that the employee performs.” Id. § 541.700. For a primary duty to be administrative, it must be “directly related to assisting with the running or servicing of the business, as distinguished, for example, from working on a manufacturing production line or selling a product in a retail or service establishment.” Bigger v. Facebook, 947 F.3d 1043, 1053 (7th Cir. 2020); see also 29 C.F.R. §

2 The IMWL also exempts from its overtime requirements employees who are employed in an administrative capacity and applies the exemption “as defined by or covered by the [FLSA] and the rules adopted under the [FLSA], as both exist on March 30, 2003.” 820 ILCS 105/4a(2)E. Accordingly, the Court refers only to the FLSA and its regulations. 3 In discussing the administrative exemption, the Court refers to Plaintiff in the singular, but notes that the analysis applies to all class and collective-action members. 541.205(b) (administrative operations of a business include “work performed by so-called white- collar employees engaged in ‘servicing’ a business as, for example, advising the management, planning, negotiating, representing the company, purchasing, promoting sales, and business research and control”). “[W]hen an employee is engaged in the core function of a business, his or her task is not properly categorized as administrative.” Schaefer-LaRose v. Eli Lilly & Co., 679 F.3d 560 (7th Cir. 2012).

According to CHRW, because CMs provide an administrative service to their customers by advising on carrier market conditions and securing appropriate capacity, they operate in an administrative capacity. See 29 C.F.R. § 541.201(c) (“An employee may qualify for the administrative exemption if the employee’s primary duty is the performance of work directly related to the management or general business operations of the employer’s customers.

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Dietrich v. C. H. Robinson Worldwide, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/dietrich-v-c-h-robinson-worldwide-inc-ilnd-2021.