Bothell v. Phase Metrics, Inc.’s Empirical Analysis
299 F.3d 1120 · 2002
Citation profile
18 federal appellate · 9 district · 5 state decisions
How this case has been cited
Cited by 69 later decisions — most recently August 2024 · most notably 115 Cal. App. 4th 715 - Bell v. Farmers Insurance Exchange (2004), Chao v. A-One Medical Services, Inc. (2003)
18 federal appellate · 9 district · 5 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedthe decision below (from California Northern District Court)
Relationships
Applies 28 U.S.C. § 1291 · 29 U.S.C. § 201 (American Samoa Labor Standards Amendments of 1956) · 29 U.S.C. § 207 · 29 U.S.C. § 213
Relies on Seminole Tribe of Florida v. Florida · Auer v. Robbins · Icicle Seafoods, Inc. v. Worthington · Rufo v. Inmates of the Suffolk County Jail · Lampl v. Four D Manufacturing Co.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he administration/production dichotomy [i]s but one piece of the larger inquiry, recognizing that a court must eonstru[e] the statutes and applicable regulations as a whole. Indeed, some cases analyze the primary duty test without referencing the [29 C.F.R.] § 541.205(a) [pre-2004] dichotomy at all. This approach is sometimes appropriate because, as we have said, the dichotomy is but one analytical tool, to be used only to the extent it clarifies the analysis. Only when work falls squarely on the production side of the line, has the administration/production dichotomy been determinative. The administration/production distinction thus distinguishes between work related to the goods and services which constitute the business’ marketplace offerings and work which contributes to running the business itself____[T]he distinction should only be employed as a tool towards answering the ultimate question, whether work is directly related to management policies or general business operations, not as an end in itself.”
10 later decisions quote this exact passage · from the majority“(a) who is compensated on a “salary basis” at a rate of at least $250 per week; and (b) whose “primary duty consists of * * * [t]he performance of office or non-manual work directly related to management policies or general business operations of his employer or his employer’s customers;” and (c) whose duties include work “requiring the exercise of discretion and independent judgment.””
4 later decisions quote this exact passage · from the majority“limits the exemption to persons who perform work of substantial importance to the management or operation of the business of his employer or his employer's customers.”
3 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.