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Strategy Considerations For Properly Applying White-Collar Exemptions For Overtime To Administrative Employees


Applicable state and federal laws, such as the Fair Labor Standards Act ("FLSA"), outline minimum wage and overtime pay obligations that hotels have to their employees. Minimum wages vary from state to state, with four states having less than the federal minimum wage of $7.25 up to Washington having a minimum wage of $9.04. Four western states (California, Nevada, Alaska and Colorado) as well as Puerto Rico and the Virgin Islands have daily overtime laws in addition to the 40-hour per week threshold established for overtime under the FLSA. Complicating matters even further for hotels are local and county ordinances that may impose additional minimum wage and overtime burdens for businesses that, for example, have contracts with a municipality and/or operate near an airport.

In this article featured on, Lonnie provides a checklist to assist those in the industry determine whether individuals employed in administrative capacities are properly classified as exempt from overtime. Although the analysis is done on a case-by-case basis and make require consultation with counsel, the test to be utilized remains constant.

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