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Helix Energy Solutions Group, Inc., et al. v. Michael J. Hewitt

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 19-20023 · judgment September 9, 2021


Decided · February 22, 2023
Pre-decision estimate: 26% cert probability (95% interval 20%–34%)

Before the decision, about 6.3× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a Fifth Circuit decision below, and a circuit split argued in the petition.

Question presented

Respondent was a supervisor on Helix's offshore vessels and was compensated commensurate with his high-ranking position. Every two weeks, Helix paid Respondent at least $963 for each day that he worked. In all, Respondent earned $248,053 in 2015, $218,863 in 2016, and $143,680 in the eight months he worked for Helix in 2017. After his performancerelated release, Respondent sued Helix under the Fair Labor Standards Act ("FLSA"), claiming that he was also entitled to substantially more in retroactive overtime pay. The FLSA sensibly exempts many highly compensated supervisors from the Act's overtime requirements. Specifically, employees who perform executive duties, earn at least $100,000 per year, and receive at least $455 per week paid on a salary basis are "deemed exempt." 29 C.F.R. §541.601(a). It is undisputed that Respondent performed executive duties and met the annual earnings threshold. Nevertheless, a sharply divided en banc Fifth Circuit ruled that Respondent was non-exempt and entitled to retroactive overtime pay because he was paid based on a daily rate, not a weekly rate, even though his daily rate was more than twice the weekly minimum. The majority reached that counterintuitive conclusion only by applying a separate provision, 29 C.F.R. §541.604, that the First and Second Circuits have both held inapplicable when determining whether highly compensated employees are exempt. The question presented is: Whether a supervisor making over $200,000 each year is entitled to overtime pay because the standalone regulatory exemption set forth in 29 C.F.R. §541.601 remains subject to the detailed requirements of 29 C.F.R. §541.604 when determining whether highly compensated supervisors are exempt from the FLSA's overtime-pay requirements.

Counsel of record

For petitioner
Paul D. Clement
Clement & Murphy, PLLC

For respondent
Samuel Charles Kaplan
Boies Schiller Flexner LLP

Case

Conference history
Distributed for 3 conferences

Amicus briefs
3 cert-stage · 8 merits
(4 supporting pet./neither, 4 respondent)

Argument & decision

Argued October 12, 2022 — Paul D. Clement · Edwin Sullivan. Audio and transcript

Decided February 22, 2023. Opinion by Kagan.

Proceedings

  1. Mar 27 2023
    Judgment issued.
  2. Feb 22 2023
    Adjudged to be AFFIRMED. Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Sotomayor, Barrett, and Jackson, JJ., joined. Gorsuch, J., filed a dissenting opinion. Kavanaugh, J., filed a dissenting opinion in which Alito, J., joined.
  3. Oct 12 2022
    Argued. For petitioners: Paul D. Clement, Alexandria, Va. For respondent: Edwin Sullivan, Houston, Tex.; and Anthony A. Yang, Assistant to the Solicitor General, Department of Justice, Washington, D. C. (for United States, as amicus curiae.)
  4. Sep 30 2022
    Reply of petitioners Helix Energy Solutions Group, Inc., et al. filed. (Distributed)
  5. Sep 28 2022
    Motion of the Solicitor General for leave to participate in oral argument as amicus curiae, for divided argument, and for enlargement of time for oral argument GRANTED.
  6. Sep 07 2022
    Brief amicus curiae of Massachusetts Nurses Association filed. (Distributed)
  7. Sep 07 2022
    Brief amicus curiae of United States filed. (Distributed)
  8. Sep 07 2022
    Brief amicus curiae of National Nurses United filed. (Distributed)
  9. Sep 07 2022
    Brief amicus curiae of American Federation of Labor and Congress of Industrial Organizations filed. (Distributed)
  10. Sep 07 2022
    Motion of the Solicitor General for leave to participate in oral argument as amicus curiae, for divided argument, and for enlargement of time for oral argument filed.
  11. Aug 31 2022
    Brief of respondent Michael J. Hewitt filed. (Distributed)
  12. Jul 21 2022
    CIRCULATED
  13. Jul 15 2022
    Brief amici curiae of States of Mississippi, et al. filed.
  14. Jul 15 2022
    Brief amici curiae of Texas Oil and Gas Association, Inc., et al. filed.
  15. Jul 15 2022
    Brief amicus curiae of The Chamber of Commerce of the United States of America filed.
  16. Jul 13 2022
    Brief amicus curiae of Independent Petroleum Association of America filed.
  17. Jul 08 2022
    Joint appendix filed (statement of cost filed.)
  18. Jul 08 2022
    Brief of petitioners Helix Energy Solutions Group, Inc., et al. filed.
  19. Jun 23 2022
    The record from the U.S.D.C. Southern District of Texas (Houston) has been electronically filed.
  20. Jun 22 2022
    Record requested from the 5th Circuit.
  21. Jun 22 2022
    The record from the U.S.C.A. 5th Circuit is electronic and located on Pacer.
  22. Jun 14 2022
    ARGUMENT SET FOR Wednesday, October, 12, 2022.
  23. Jun 07 2022
    May 26, 2022 motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioners' brief on the merits is extended to and including July 8, 2022. The time to file respondent's brief on the merits is extended to and including August 31, 2022.
  24. May 26 2022
    Motion for an extension of time to file the briefs on the merits filed.
  25. May 06 2022
    Motion for an extension of time to file the briefs on the merits filed.
  26. May 02 2022
    Petition GRANTED.
  27. Apr 25 2022
    DISTRIBUTED for Conference of 4/29/2022.
  28. Apr 06 2022
    DISTRIBUTED for Conference of 4/22/2022.
  29. Apr 05 2022
    Reply of petitioners Helix Energy Solutions Group, Inc., et al. filed. (Distributed)
  30. Mar 21 2022
    Brief of respondent Michael J. Hewitt in opposition filed.
  31. Feb 18 2022
    Response Requested. (Due March 21, 2022)
  32. Feb 16 2022
    DISTRIBUTED for Conference of 3/4/2022.
  33. Feb 10 2022
    Brief amici curiae of Independent Petroleum Association of America and Offshore Operators Committee filed.
  34. Feb 10 2022
    Brief amici curiae of Mississippi, et al. filed.
  35. Feb 09 2022
    Waiver of right of respondent Michael J. Hewitt to respond filed.
  36. Feb 09 2022
    Brief amici curiae of Texas Oil and Gas Association, Inc. and The American Petroleum Institute filed.
  37. Feb 07 2022
    Letter of February 7, 2022 pertaining to amicus briefs, received from counsel for the petiitoners.
  38. Jan 27 2022
    Letter of January 25, 2022 pertaining to the corporate discosure statement, received from counsel for the petiitoners.
  39. Jan 25 2022
    Blanket Consent filed by Petitioner, Helix Energy Solutions Group, Inc., et al.
  40. Jan 07 2022
    Petition for a writ of certiorari filed. (Response due February 10, 2022)