What happened
A D.C. federal judge granted summary judgment to the U.S. Small Business Administration administrator and denied former SBA employee Nia Lucas' partial summary judgment bid in a Fair Labor Standards Act dispute over shutdown-related overtime and alleged retaliation.
Lucas sued under the FLSA seeking compensation for overtime she said she worked on one day during the January 2018 federal government shutdown. According to the opinion, the number of hours she claimed shifted during the case from two to five, and her current demand was about $361.30 plus liquidated damages and interest.
The opinion describes Lucas as a former SBA program analyst who had a telework accommodation and an alternative work schedule. The court said she had been instructed repeatedly that overtime had to be authorized in advance, while shutdown guidance from the agency gave employees varying estimates for how long orderly shutdown activities should take.
Lucas maintained that she performed shutdown activities on Jan. 22, 2018, and should have been paid more. The opinion says she was paid for four hours of overtime in the pay period that included the furlough, and that none of her colleagues received overtime pay for that period.
On the retaliation count, the court held that Lucas' March 2020 settlement and release agreement with the SBA barred the claim. The opinion says Lucas released broad categories of claims, received $80,000 in consideration and was represented by private counsel who signed the agreement.
The court also said the retaliation theory would fail even if it were not barred, because Lucas had not produced evidence creating a jury question. In granting summary judgment on that count, the court cited the "lack of a material dispute of fact" on retaliation.
The opinion concludes by denying Lucas' partial summary judgment motion and granting the administrator's motion for summary judgment, with a separate order to issue.