Federal District Court Denies Summary Judgment to J.P. Morgan Chase as to Whether Its Hedge Fund Accounting Business Employees Were Exempt from Fair Labor Standards Act Overtime Pay Requirements

Plaintiff Damian Hendricks (Hendricks) was a “Fund Accounting Specialist” in the “Hedge Fund Services” business of defendant J.P. Morgan Chase Bank (JPMorgan).  Plaintiff Michael Minzie (Minzie) was a “Fund Accounting Analyst” in that business.  They performed various services in connection with JPMorgan’s preparation of financial statements for hedge fund clients.  Both were paid a weekly salary and were eligible for bonuses.  They claimed on behalf of themselves “and on behalf of other similarly situated individuals” that JPMorgan failed to pay them overtime in violation of the federal Fair Labor Standards Act (FLSA).  Following discovery and depositions, JPMorgan moved for summary judgment, claiming that Hendricks and Minzie were exempt from the FLSA overtime requirements because they were both employed in bona fide professional and administrative capacities.  In a decision that serves as an excellent primer on the applicability, in the hedge fund context, of exemptions from overtime pay under the FLSA and the analogous Connecticut law, the district court denied the motion, holding that there were significant issues of fact as to the nature of the employees’ duties.  We summarize the factual allegations and the court’s decision.

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