Rejecting a claim that the position lacked “discretion and independent judgment,” an Indiana Federal Court recently found a trauma registrar for a Level III Trauma Center to be an exempt administrative employee. Brown v. Ind. Univ. Health Ball Mem’l Hosp., 2015 U.S. Dist. LEXIS 141921 (S.D. Ind. Oct. 19, 2015).

In Brown, plaintiff was a trained EMT who worked in various hourly capacities in the emergency department of the defendant, a tertiary referral center and teaching hospital in East Central Indiana. She applied for and was promoted to the Trauma Registrar position, a salaried exempt position which, per the job description, was “accountable for prioritizing and coordinating the activities for the Trauma Registry in order to meet schedules and deadlines, maintain current and accurate procedures and practices.” After her employment ended, she brought suit alleging she had been misclassified as exempt from overtime in the Trauma Registrar role, specifically alleging that the position did not require “discretion and independent judgment with respect to matters of significance.” Judge Jane Magnus-Stinson rejected this claim, characterizing it as an “attempt to recast her main duties as only related to data entry” which ignored Plaintiff’s decision-making role in 1) developing procedures for the trauma registry, 2) serving as the “voice” of the hospital for various community outreach program; and, 3) independently developing community programs targeted towards injury prevention (such as bicycle safety programs).

The administrative exemption remains the least concrete – and thus hardest to define – of the “white collar” exemptions, giving rise to continued questions in its application for compliance purposes and in litigation.