Anani v. CVS RX SERVICES, INC.
Salah Anani, a former pharmacist, sued CVS RX Services, Inc. alleging unpaid overtime compensation under the Fair Labor Standards Act (FLSA) and New York Labor Law. Anani, classified as a bi-weekly salaried pharmacist, received a base salary and additional premium pay for hours exceeding 44 per week. He contended he was misclassified as exempt and was entitled to time-and-a-half overtime. CVS argued Anani was properly exempt under the FLSA's professional and highly compensated employee provisions. The court determined Anani met the 'learned professional' duties test and the central issue was the salary basis test. The court concluded that Anani's compensation scheme, which included a guaranteed base salary and premium pay for additional hours, adhered to FLSA salary basis requirements and associated regulations. Consequently, the court granted CVS's motion for summary judgment, thereby dismissing Anani's complaint.