Edwards v. Jet Blue Airways Corp.
Glenn Edwards initiated a putative class action against Jet Blue Airways Corporation, alleging violations of New York Labor Law, article 19, § 650 et seq., concerning overtime compensation. Edwards claimed that Jet Blue failed to pay him at 1.5 times his regular rate for hours worked beyond 40 that were exchanged with coworkers. Jet Blue sought to dismiss the complaint, asserting an exemption under the Fair Labor Standards Act (FLSA) § 213 (b) (3) for air carriers, which it argued was incorporated into New York's 12 NYCRR 142-2.2. The court acknowledged the applicability of the FLSA exemption to Edwards due to Jet Blue's status as an air carrier. However, the court ruled that 12 NYCRR 142-2.2 still mandates overtime pay at 1.5 times the basic minimum hourly rate for exempt employees, which in this context means their regular pay rate plus one half times the New York State minimum wage. Finding that Edwards' complaint sufficiently alleged inadequate overtime compensation under New York law based on this calculation, the court denied Jet Blue's motion to dismiss.