Helix Energy Solutions v. Hewitt
In brief
A worker paid by the day is generally entitled to overtime unless the employer meets the specific salary-basis conditions for an executive exemption.
- Where it stands
- Decided
Decided 6-3 · February 22, 2023 · Opinion by Justice Kagan
- What it’s about
- Michael Hewitt, an offshore oil rig supervisor paid a daily rate totaling over $200,000 annually, sued his employer for overtime pay under the Fair Labor Standards Act.
- Who it affects
- Employers cannot avoid overtime obligations simply because a daily-rate supervisor earns a high annual income. For example, a worker paid more than $200,000 a year by the day may still be entitled to overtime if the salary-basis conditions are not met.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that daily-rate workers are not exempt from overtime pay as bona fide executives unless they meet specific salary basis conditions, meaning Hewitt was entitled to overtime.
The decision clarifies that pay structure, not income alone, determines whether highly paid daily-rate workers can be denied overtime.
Question presented
Whether a supervisor who is paid a daily rate—and thus is not paid on a “salary basis” under 29 C.F.R. § 541.602(a)—may nevertheless be exempt from the Fair Labor Standards Act’s overtime-pay requirements because he is a “highly compensated employee” under 29 C.F.R. § 541.601?
What the Court decided
The vote
From the opinions
““Daily-rate workers, of whatever income level, qualify as paid on a salary basis only if” they meet the conditions in §541.604(b).”
What's next
Lower courts will apply the Court's rule in overtime disputes involving daily-rate workers. Employers may need to review pay plans and overtime practices for highly paid supervisors paid by the day.
Documents
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
New analysis added
AI analysis generated: Case Briefing
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Case data updated: status, opinion_date
Opinion added: Hewitt
Opinion added: opinion
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Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Helix Energy Solutions v. Hewitt?
- The Court ruled that Hewitt was not exempt from overtime. His daily-rate pay did not satisfy the required salary-basis conditions.
- Who is affected by the Helix Energy Solutions decision?
- Highly paid supervisors and other workers paid by the day may be affected. Employers must evaluate whether their pay plans meet the salary-basis conditions.
- What happens next after Helix Energy Solutions v. Hewitt?
- Lower courts must follow the decision in similar overtime cases. Employers may review daily-rate jobs and adjust payroll practices where needed.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.