Takeaway: An employee who repaired hydraulic cranes that were permanently affixed to trucks and could travel on highways was exempt from the FLSA's overtime compensation requirements because he was a mechanic under the Motor Carrier Act.

A worker who repaired hydraulic cranes that were permanently affixed to trucks and could travel on highways was not entitled to overtime compensation under the Fair Labor Standards Act (FLSA), a federal appeals court held. The employee was exempt from the FLSA's overtime compensation requirements because he was a mechanic under the Motor Carrier Act (MCA), the court ruled.

The employer owned and leased self-propelled, hydraulic cranes to companies for projects in oil fields. The cranes—which were permanently affixed to a truck chassis and could legally travel on highways—were transported to customer jobsites throughout the southern and southwestern United States. The employee traveled to these sites and other office locations where the cranes were stored to perform repairs and maintenance on the hydraulic, electrical and pneumatic systems in the cranes. On average, the employee serviced five to 20 cranes a week and would travel out of state to service these cranes several times a month, if not several times a week. He estimated that he worked, on average, 80 hours per week.

The worker was employed in this position for approximately three years. Initially, he was paid hourly and received overtime compensation, but after about a year,...

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