First Circuit Confirms What Every Bride Knows: Event Planning Requires Discretion and Independent Judgment

On November 28, 2011, the U.S. Court of Appeals for the First Circuit issued a decision in Hines v State Room, Inc. finding that sales managers for a Boston banquet facility were exempt from overtime under the Fair Labor Standards Act’s administrative exemption.  The case is certain to become a key precedent for employers in two ways.  First, it aids employers in arguing that employees in sales-related job positions meet the “duties test” for the administrative exemption.  Second, the case clarifies that the discretion and independent judgment analysis necessary for application of the administrative exemption should not be unnecessarily rigid.

The court determined that the plaintiffs’ job functions ­– which included working with clients to design customized weddings and other events and securing contracts for those events – were properly considered administrative because they were ancillary to the employer’s principal business function of actually providing banquet services.  The court also found that the job involved the exercise of independent judgment and discretion because acting as the face of the company and “engaging potential clients and assisting them in selecting from various options from the employers’ offerings” required “invention, imagination and talent.” 

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