The Fifth Circuit Court of Appeals ruled on September 3, 2026, that lieutenants and captains in the Harris County Sheriff’s Office are not entitled to overtime pay under the Fair Labor Standards Act (FLSA). The court's decision affects law enforcement personnel in Harris County, Texas, and clarifies the criteria for overtime exemptions for government employees.
The case, Moreau v. Harris County, was filed under docket number 25-20045. The plaintiffs, including Lynwood Moreau and others, argued that they were denied overtime compensation despite working more than 40 hours per week. Harris County contended that these employees qualified as exempt administrative and executive employees under the FLSA, which would exclude them from receiving overtime pay.
The dispute began when Moreau and several other officers filed a lawsuit against Harris County, claiming violations of the FLSA. They alleged that the county failed to pay them overtime for hours worked beyond the standard 40-hour workweek. The case was consolidated with three others, and the district court initially ruled in favor of the plaintiffs, allowing their claims to proceed to trial.
During the trial, the jury found that the plaintiffs were exempt from overtime pay under both the administrative and executive exemptions of the FLSA. The plaintiffs subsequently filed a motion for judgment as a matter of law, arguing that the jury's verdict was inconsistent and that the magistrate judge had erred in submitting certain questions of law to the jury. However, the court ruled that the magistrate judge did not err in any of these respects.
The Fifth Circuit, led by Judge Stephen A. Higginson, affirmed the lower court's ruling, stating, "We conclude that the magistrate judge correctly determined plaintiffs are paid on a salary basis, did not err in charging the jury, and did not err in denying plaintiffs’ renewed motion for judgment as a matter of law or motion for a new trial." The court emphasized that Harris County had met its burden of proving that the officers were exempt from overtime pay.
The ruling is significant as it clarifies the application of the FLSA exemptions for law enforcement personnel. The court noted that the exemptions apply to employees who meet specific criteria, including being compensated on a salary basis and performing duties related to management or general business operations. The court found that the lieutenants and captains in question met these criteria, as their primary duties involved administrative tasks related to the management of the Harris County Sheriff’s Office.
This decision may have broader implications for other law enforcement agencies and government employees across the country. It reinforces the interpretation of the FLSA exemptions, particularly for those in managerial roles within public service. The ruling may also influence future cases involving overtime pay disputes, as it sets a precedent for how courts interpret the administrative and executive exemptions.
Going forward, the ruling in Moreau v. Harris County may not be appealed further, as the Fifth Circuit has issued its final decision on the matter. However, similar cases could arise, and the legal standards established in this case will likely be referenced in future litigation involving overtime pay and employee classifications under the FLSA.