Martinez v. Superior HealthPlan, Inc.
Plaintiffs, sales representatives for Superior HealthPlan, Inc., alleged misclassification as independent contractors and sought overtime wages under the FLSA, along with claims under ERISA and COBRA. The ERISA and COBRA claims were previously dismissed. Defendants Superior HealthPlan, Inc. and Centene Corporation moved for summary judgment, arguing Plaintiffs were independent contractors or exempt outside sales employees. The Court, without ruling on the independent contractor status, focused on the outside sales employee exemption. It found that Plaintiffs' primary duty was making sales away from the employer's business and that they met the external indicia for outside salespersons, despite some employer supervision. Consequently, the Court granted partial summary judgment in favor of Defendants, concluding that Plaintiffs were exempt outside sales agents as a matter of law. Superior's counterclaims for overpayment against two plaintiffs remain pending.