Harris v. Superior Court, 53 Cal.4th 170 (2011)

Plaintiffs in this case are claims adjusters employed by two insurance companies. They filed four putative class actions, claiming they had been erroneously classified as exempt administrative employees and seeking damages based upon unpaid overtime. The court of appeal held as a matter of law that plaintiffs were non-exempt employees who were entitled to overtime pay. In this opinion, the California Supreme Court reversed the court of appeal and remanded the action with directions that the appellate court apply the appropriate legal standard. The Supreme Court stated that “[t]he precise question here is whether plaintiffs’ work as claims adjusters is encompassed by the expanded language of the statute, wage orders, and federal regulations that delineate what work qualifies as administrative.” The Court further held that while the “administrative/production worker dichotomy” (cited by the lower court) may be used as an “analytical tool,” it was improperly applied in this case as a “dispositive test.” Finally, the Supreme Court noted that it was “express[ing] no opinion on the strength of the parties’ relative positions.”