Plaintiff Heather Winesburg sued defendants Stephanie Morris Nissan, LLC, Stephanie Morris, and Robbie Howard in the United States District Court for the Western District of Missouri raising claims of violations of the Fair Labor Standards Act (FLSA), Missouri Minimum Wage and Hour Law (MWHL), and unjust enrichment. Before the court is Defendants’ motion for summary judgment.
Statement of Undisputed Facts
Winesburg worked as an office manager at Stephanie Morris Nissan, LLC in Sedalia, Missouri for approximately two months, from June 7, 2022, to September 1, 2022. She was paid a salary of $7,000 per month. Her job duties included booking customer deals, making daily deposits, filing customer paperwork, researching data, managing vehicle floor plans, helping customers, answering phones, organizing and training new employees, and implementing company policies.
The parties disagree on the nature and extent of Winesburg’s responsibilities, particularly regarding her role in managing the dealership’s floor plan (inventory financing). Defendants characterize Winesburg as a manager of the program, while Winesburg contends her role was more akin to data entry. There is also disagreement about Winesburg’s check-signing authority and whether it involved independent decision-making or was merely clerical.
Legal Analysis
FLSA and MWHL Claims: The court analyzed whether Winesburg qualified for the administrative capacity exemption under the FLSA and MWHL. This exemption requires that an employee: (1) be compensated on a salary basis of at least $684 weekly, (2) have a primary duty of performing office work directly related to management or general business operations, and (3) exercise discretion and independent judgment on matters of significance.
The court found that the first prong was satisfied, as Winesburg’s salary met the threshold. For the second prong, the court determined that Winesburg’s work related to the dealership’s floor plan involved finance, accounting, budgeting, purchasing, and procurement, which are typically considered management or general business operations.
However, the court found a genuine issue of material fact regarding the third prong. The parties disputed whether Winesburg’s job involved independent decision-making or was more ministerial in nature. The court noted that Winesburg’s brief tenure in the role complicated the determination of whether her primary duty involved exercising independent judgment.
Unjust Enrichment Claim: The court granted summary judgment to the defendants on this claim. It found that the existence of a valid employment contract, evidenced by email communications between Winesburg and the defendants, precluded an unjust enrichment claim under Missouri law.
The court denied summary judgment on Winesburg’s FLSA and MWHL claims (Counts One and Two) due to genuine issues of material fact regarding the nature of her job duties, but granted summary judgment to the defendants on the unjust enrichment claim (Count Three).
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