Solt v. CSA America Testing & Certification LLC

CourtDistrict Court, W.D. Washington
DecidedSeptember 24, 2025
Docket2:24-cv-00112
StatusUnknown

This text of Solt v. CSA America Testing & Certification LLC (Solt v. CSA America Testing & Certification LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Solt v. CSA America Testing & Certification LLC, (W.D. Wash. 2025).

Opinion

6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 7 AT SEATTLE 8

9 DENA SOLT, an individual, Case No. 2:24-cv-00112-RSM 10 Plaintiff, ORDER GRANTING DEFENDANT’S 11 MOTION FOR SUMMARY JUDGMENT v. 12

13 CSA AMERICA TESTING & CERTIFICATION LLC, d/b/a CSA GROUP, 14 a foreign limited liability company, et al.,

15 Defendant. 16

17 This matter comes before the Court on Defendant CSA America Testing & Certification 18 (“CSA”)’s Motion for Summary Judgment, Dkt. #71. Plaintiff Dena Solt has filed an opposition 19 brief. Dkt. #85. Neither party has requested oral argument. For the reasons below, the Court 20 GRANTS CSA’s Motion. 21 22 Plaintiff Solt worked for Defendant CSA from 2019 until her termination in April of 23 2023. She alleges wage claims for overtime and unpaid meal periods and rest breaks, breach of 24 contract, promissory estoppel, a hostile work environment, sex and age discrimination in 25 violation of RCW 49.60.180, and retaliation. See Dkt. #29. 26 27 Summary judgment is appropriate where “the movant shows that there is no genuine 28 dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986). Material facts are 1 2 those which might affect the outcome of the suit under governing law. Anderson, 477 U.S. at 3 248. In ruling on summary judgment, a court does not weigh evidence to determine the truth of 4 the matter, but “only determine[s] whether there is a genuine issue for trial.” Crane v. Conoco, 5 Inc., 41 F.3d 547, 549 (9th Cir. 1994) (citing Federal Deposit Ins. Corp. v. O’Melveny & Meyers, 6 969 F.2d 744, 747 (9th Cir. 1992)). 7 8 On a motion for summary judgment, the court views the evidence and draws all 9 reasonable inferences in the light most favorable to the non-moving party. Anderson, 477 U.S. 10 at 255; Sullivan v. U.S. Dep’t of the Navy, 365 F.3d 827, 832 (9th Cir. 2004). However, the 11 nonmoving party must make a “sufficient showing on an essential element of her case with 12 13 respect to which she has the burden of proof” to survive summary judgment. Celotex Corp. v. 14 Catrett, 477 U.S. 317, 323 (1986). “The mere existence of a scintilla of evidence in support of 15 the plaintiff's position will be insufficient; there must be evidence on which the jury could 16 reasonably find for the plaintiff.” Anderson, 477 U.S. at 251. 17 The Court will address each claim below. 18 19 A. Overtime Claim and Administrative Exemption 20 The Fair Labor Standards Act (“FLSA”) deals with overtime and minimum wage 21 requirements for employees. 29 U.S.C. §§ 201–219. Washington’s Minimum Wage

22 Requirements and Labor Standards, formerly known as the Minimum Wage Act (“MWA”), is 23 based upon the FLSA, and federal authority under the FLSA often provides helpful guidance. 24 25 Drinkwitz v. Alliant Techsystems, Inc., 140 Wn.2d 291, 298, 996 P.2d 582, 586 (2000). “The 26 FLSA requires employers to pay overtime to covered employees who work more than 40 hours 27 in a week.” Encino Motorcars, LLC v. Navarro, 584 U.S. 79, 81 (2018) (citing 29 U.S.C. § 28 207(a)). However, the FLSA exempts from overtime pay “any employee employed in a bona fide 1 2 executive, administrative, or professional capacity.” 29 U.S.C. § 213(a)(1). 3 An employee qualifying for the administrative exemption must (1) be compensated not 4 less than $455 per week; (2) perform as her primary duty “office or non-manual work related to 5 the management or general business operations of the employer or the employer's customers;” 6 and (3) have as her primary duty “the exercise of discretion and independent judgment with 7 8 respect to matters of significance.” McKeen-Chaplin v. Provident Sav. Bank, FSB, 862 F.3d 847, 9 850-51 (9th Cir. 2017) (citing 29 C.F.R. § 541.200(a)). “These three conditions are explicit 10 prerequisites to exemption, not merely suggested guidelines.” Id. at 851. The defendant bears 11 the burden of proving the exemption applies. Id. The “question of how an employee spends his 12 13 or her workday is one of fact, while the question of whether his or her activities exclude him or 14 her from the overtime-pay requirement is one of law.” Christopher v. SmithKline Beecham Corp., 15 635 F.3d 383, 391 (9th Cir. 2011). 16 CSA paid Solt an annual salary of $135,000 as a Certifier III, which increased to $141,075 17 upon her promotion to Certification Specialist in January 2021. Dkt. #79 (“KC Fletcher Decl.”), 18 19 ¶ 3; Dkt. #115 at 2. Solt was paid on a biweekly basis. Dkt. #82, Ex. 2, (“Solt Dep.”) at 245:12- 20 17. The amount of compensation received by Plaintiff at all relevant times exceeded the $455 21 per week threshold, thus satisfying the first prong. 22 The parties dispute whether Solt’s primary duties were directly related to the management 23 or general business operations of CSA or its customers. To meet this requirement, the employee 24 25 “must perform work directly related to assisting with the running or servicing of the business, as 26 distinguished, for example, from working on a manufacturing production line or selling a product 27 in a retail or service establishment.” 29 C.F.R. 541.201(a). “Work directly related to management 28 or general business operations includes, but is not limited to, work in functional areas such as tax; 1 2 finance; accounting; budgeting; auditing; insurance; quality control; purchasing; procurement; 3 advertising; marketing; research; safety and health; personnel management; human resources; 4 employee benefits; labor relations; public relations, government relations; computer network, 5 internet and database administration; legal and regulatory compliance; and similar activities.” 29 6 C.F.R. 541.201(b). 7 8 CSA cites to the job description for Certifier III, which states the primary function of the 9 role is to “provid[e] certification services,” which requires the “interpretation of standards, 10 processes and procedures, as well as providing technical guidance; analysis; product testing 11 information; compliance and maintenance recommendations; technical reviews and independent 12 13 checks.” Dkt. #79-1 at 2. The Certification Specialist job description expands on these duties by 14 adding that the employee will “make[] technical decisions based on a high degree of knowledge, 15 training and professional experience to maintain the integrity of CSA’s global certification 16 programs.” Dkt. #79-2 at 2.

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Solt v. CSA America Testing & Certification LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/solt-v-csa-america-testing-certification-llc-wawd-2025.