Instructor exempt from overtime under Massachusetts Wage Act

A state Superior Court judge has ruled that an instructor at a for-profit commercial truck-driving school was not entitled to overtime pay under the state Wage Act, concluding that the employee qualified as an exempt teaching professional.

The plaintiff worked as a commercial driver’s license (CDL) instructor and later as a lead instructor for a for-profit tractor-trailer training school.

After his termination, he brought a state Wage Act claim alleging that he was owed overtime pay for more than 1,400 hours worked over 40 hours per week. He argued that a Wage Act provision expressly exempting employees of nonprofit schools from overtime reflected a legislative intent to extend overtime protections to employees of for-profit educational institutions.

The court rejected that interpretation. In dismissing the case, the judge emphasized that a separate provision of the Wage Act exempts “bona fide professional” employees from overtime requirements.

Massachusetts regulations provide that the term “bona fide professional” is defined consistent with federal regulations, which expressly include teachers engaged in automobile driving instruction. Because the plaintiff’s primary role was instructional, the court concluded that he fell squarely within the professional exemption.

The judge also declined to merge or “graft together” different Wage Act exemptions to reach a contrary result, noting that doing so would produce illogical outcomes inconsistent with the statute’s structure.

The court further found that allegations regarding non-instructional tasks, such as scheduling or facility upkeep, were insufficient to overcome the teaching-professional exemption, particularly where teaching was the employee’s primary duty.

The decision underscores that courts continue to look closely to federal wage-and-hour regulations when interpreting the state’s overtime exemptions.

For employers, the ruling highlights the importance of accurately assessing an employee’s primary job duties, particularly in instructional or training roles, when determining overtime eligibility under the Wage Act.