Victor Treatment Centers v. Troutman CA3

BACKGROUND

VTC runs residential treatment homes for emotionally disturbed children and young adults. Troutman was employed by VTC as a residential services supervisor responsible for managing one of the VTC homes. In 2012, Troutman filed a complaint with the Labor Commissioner’s Office, alleging that her employer, VTC, improperly treated her as an exempt employee not entitled to overtime pay. After a hearing, the Labor Commissioner found that Troutman was nonexempt and thus entitled to overtime pay because Troutman “spent a majority of her time (more than 50 percent) engaged in duties of manual work or direct care.” The Labor Commissioner awarded Troutman $28,519.47 in wages, $8,741.60 in liquidated damages under the Labor Code, and $1,480.23 in interest.1 VTC filed a notice of appeal de novo in the superior court. Over the course of several days, the superior court conducted a trial without a jury during which the parties provided documentary and testimonial evidence. After trial, neither party requested a statement of decision, so the trial court entered judgment. It concluded that Troutman’s position at VTC as a residential services supervisor was exempt from overtime pay. The…