Hurt v. Commerce Energy, Inc.

92 F. Supp. 3d 683, 2015 U.S. Dist. LEXIS 29311, 2015 WL 1039761
CourtDistrict Court, N.D. Ohio
DecidedMarch 10, 2015
DocketCase No. 1:12-CV-00758
StatusPublished
Cited by4 cases

This text of 92 F. Supp. 3d 683 (Hurt v. Commerce Energy, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hurt v. Commerce Energy, Inc., 92 F. Supp. 3d 683, 2015 U.S. Dist. LEXIS 29311, 2015 WL 1039761 (N.D. Ohio 2015).

Opinion

OPINION & ORDER [Resolving Doc. 810]

JAMES S. GWIN, District Judge.

This is a case about minimum wage and overtime pay under the Fair Labor Standards Act (“FLSA”)1 and overtime pay under the Ohio Minimum Fair Wage Standards Act (“Ohio Wage Act”).2 Plaintiffs are door-to-door workers who solicited residential customers for the Defendants’ energy services.

Following a trial on the merits, a jury found Defendants liable for violations of the FLSA and the Ohio Wage Act.3 Defendants now renew the motion for judgment as a matter of law they made at trial. In the alternative, Defendants move for a new trial, or to certify an interlocutory appeal of the liability phase of the trial. For the following reasons, the Court DENIES the motion for judgment as a matter of law, DENIES the motion for a new trial, and DENIES the motion to certify an interlocutory appeal.

I. Background

The Court has previously issued an opinion detailing the factual background of this case and incorporates that background by [687]*687reference.4 In short, Defendants sell electricity and natural gas to residential and commercial customers in the United States and Canada. Under Defendant’s selling scheme, Plaintiffs would go door to door to obtain applications from potential customers. An application could then become final contract after a verification call between the customer and a third-party verifier and after the Defendant found the customer’s credit satisfactory. Plaintiffs were paid commission for every finalized contract; if an application was rejected for any reason before the contract became final, the- employee would not be paid.

Plaintiffs brought suit, alleging this commission-based compensation system deprived them of minimum wage and overtime. Two classes were certified: a nationwide FLSA collective action seeking minimum wage and overtime under federal law, and a Rule 23 class action seeking overtime under Ohio law. Against these claims, Defendants argued that Plaintiffs were exempt from overtime and minimum wage requirements because of the “outside salesperson” exemption.

The Court held a trial on Defendants’ liability from September 29, 2014, to October 6, 2014.5

At the close of Plaintiffs’ case, Defendants moved for judgment as a matter of law6 on two grounds. First, Defendants argued that the Ohio “Badge Never Used” (“BNU”) group of employees — those who attended at least one day of training but never obtained a completed application from a customer — had not established that any member of the group had worked more than forty hours in a week, and thus had failed to prove their claim for overtime wages.7 Second, Defendants argued that Plaintiffs’ evidence established that Plaintiffs were exempt outside salespeople.8 The Court denied both motions, finding there was sufficient evidence for both issues to go to the jury.

At the close of Defendants’ case, Defendants and Plaintiffs cross-moved for judgment as a matter of law regarding the application of the outside salesperson exemption.9 The Court denied both motions.

Defendants also raised several objections to the jury instructions. Relevant to this motion, they argued that the Court erred in instructing the jury that it could consider whether the applications obtained by Plaintiffs were binding commitments in deciding whether the transactions were “sales” for purposes of the FLSA.10

Finally, Defendants also object to the Court twice instructing the jury during the trial that an employment contract cannot waive FLSA minimum wage and overtime requirements if those requirements would otherwise apply.11

[688]*688II. Judgment as a Matter of Law

Defendants renew their motion for judgment as a matter of law. They raise three issues, which will be addressed in turn. First, that there was insufficient evidence that the Plaintiffs qualified for the outside salesperson exemption. Second, that no evidence supports the inference that any BNU group member worked more than 40 hours in any week. And third, that the Court’s instruction to the jury that the minimum wage requirements of the FLSA cannot be waived prejudiced their case. All three arguments lose.

Before moving on to the merits of this motion, the Court pauses to chastise both sides for their complete and utter failure to cite to the trial record or admitted exhibits in their briefing.12 Judge Easter-brook once wrote, regarding summary judgment, that, “[district judges are not archaeologists. They need not excavate masses of papers in search of revealing tidbits — not only because the rules of procedure place the burden on litigants, but also because their time is scarce.”13 The same goes for post-trial motions. When the issues all relate to what happened at trial, the parties should point to specific evidence that appears in the record to support their positions, rather than relying on generalized statements and their own (occasionally faulty) memories as they did here. In the future, both parties and their counsel would do well to respect the Court’s limited resources and not force it to do their jobs for them.

A. Legal Standard

A motion for judgment as a matter of law under Rule 50(a) requires the trial court to decide “whether there was sufficient evidence presented to raise a material issue of fact for the jury.”14 The Court “must view the evidence in the light most favorable to the party against whom the motion is made, and give that party the benefit of all reasonable inferences.”15 “ ‘[Sufficient evidence’ will be found unless, when viewed in the light of those inferences most favorable to the nonmov-ant, there is either a complete absence of proof on the issues or no controverted issues of fact upon which reasonable persons could differ.”16 The Court neither weighs the evidence, evaluates the credibility of the witnesses, nor substitutes its judgment for that of the jury.17

B. Analysis

1. Outside Sales Exemption

Defendants first argue that they should receive judgment as a matter of law because Defendants established, and Plaintiffs failed to rebut, that Plaintiffs meet the definition of outside salespeople.18 While Defendants’ motion largely objects to the contents of the jury instructions themselves, which is discussed in more detail below, Defendants also raise arguments regarding the sufficiency of the evi-[689]*689denee that are properly considered on motion for judgment as a matter of law.19

Generally, the FLSA requires employers to pay employees a minimum wage, as well as time-and-a-half overtime pay when the employee works more than forty hours in a week.20 Not all employees, however, are protected by this requirement. One exception is that “any employee employed ... in the capacity of outside salesman” is not entitled to minimum wage or overtime.21 An outside salesperson is “any employee ...

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Related

Davina Hurt v. Commerce Energy, Inc.
973 F.3d 509 (Sixth Circuit, 2020)
Martinez v. Superior HealthPlan, Inc.
371 F. Supp. 3d 370 (W.D. Texas, 2019)
Flood v. Just Energy Mktg. Corp.
904 F.3d 219 (Second Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
92 F. Supp. 3d 683, 2015 U.S. Dist. LEXIS 29311, 2015 WL 1039761, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hurt-v-commerce-energy-inc-ohnd-2015.