Talking Turkey—What Butterball’s Overtime Win Means for Employers

When an employee claims they weren't paid properly for overtime, it can send shivers down any employer's spine. But a recent Fourth Circuit decision offers a reassuring reminder that good documentation and clear pay practices can win the day.

In Figueroa v. Butterball, LLC, decided January 13, 2026, the appellate court affirmed summary judgment for the employer on claims under the Fair Labor Standards Act (FLSA) and dismissed claims under the North Carolina Wage and Hour Act (NCWHA).

Let’s talk turkey (I’m sorry, I couldn’t help it!)

What Happened Here?

Well, the employee, Mr. Figueroa worked as a night-shift turkey loader.

Basically, his job involved catching and loading turkeys onto trucks for transport, typically working Sunday evenings through Friday or Saturday mornings.

When Mr. Figueroa was hired, he signed an offer letter explicitly stating that Butterball would pay him “a load rate of $10.80,” a classic piece-rate compensation arrangement. His paystubs reflected this structure, showing pay entries labeled “LoadTrip” for base pay, “OT Hours” for overtime, and “AttendHr” for total hours worked.

Despite signing the offer letter and receiving these paystubs for years, Figueroa later sued Butterball, claiming he was actually an hourly employee and that Butterball shorted him on overtime.

Let’s Learn About Piece-Rate Overtime

Look, I’m just trying to bring some excitement into your day.

The FLSA does not require employers to pay employees on an hourly basis-employees may be compensated through piece-rate, salary, commission, or other systems. For piece-rate employees, the overtime calculation works like this:

1. Add up the employee’s total earnings for the workweek from piece rates and all other sources.

2. Divide that total by the hours worked that week to get the employee's “regular rate” for the week.

3. Multiply half of that regular rate by the number of hours worked over 40.

This means piece-rate employees receive their full piece-rate earnings plus a “half-time” premium for overtime hours.

This is not the “time-and-a-half” rate that hourly employees receive.

Butterball Prevails On Summary Judgment! But Why?

The Fourth Circuit affirmed summary judgment for Butterball on the FLSA claim and upheld the dismissal of Mr. Figueroa’s state law claims.

First, the court found that Figueroa was indisputably a piece-rate employee, not an hourly employee.

Why?

Well, it may have to do with the signed offer letter stating a “load rate.” The court found this document to be compelling evidence.

Other evidence included testimony from a supervisor confirming that employees were told they would be paid “strictly per load rate” and the testimony of other employees that they understood they were being paid per load, not by the hour.

Second, the court found that Butterball properly calculated overtime under the FLSA’s piece-rate formula. The court walked through an example workweek showing that Butterball correctly divided total weekly earnings by hours worked to determine the regular rate, then paid the required half-time premium for overtime hours.

The court impressively did a lot of math for this one.

Finally, the court found that a “mutual understanding” existed between Butterball and its employees that piece-rate pay was intended to cover all hours worked—both productive loading time and nonproductive time like traveling or waiting.

What Employers Can Learn

1. Get it in writing and signed. Butterball’s signed offer letter was critical to its defense. If you pay employees on a piece-rate, commission, or other non-hourly basis, document that clearly in your offer letters and ensure employees sign them. A plaintiff who signed a document stating a “load rate” will have a very hard time later claiming he was promised hourly wages.

2. Ensure paystubs are consistent. Paystubs used the term “LoadTrip” for base pay-reinforcing the piece-rate structure. Confusing or ambiguous paystubs can create unnecessary headaches in litigation. Design your paystubs so that they clearly reflect the compensation arrangement you have with your employees.

3. Ensure supervisors are on the same page. Supervisor testimony that prospective hires were told they would be paid “strictly per load rate” helped establish that the company consistently communicated its pay structure. Train managers and HR personnel to describe compensation accurately and consistently during onboarding. Those conversations can become key evidence later.

4. Remember that “mutual understanding” matters. If you pay employees piece-rate and expect that pay to cover all hours worked (including nonproductive time), make sure there is a mutual understanding of that arrangement. The good news is that this understanding does not need to be in writing. Indeed, it can be inferred from your practices, such as not requiring employees to differentiate between productive and nonproductive hours on their timesheets. Still, the safer practice is to explain this clearly at the time of hire.

The bottom line is this: clear documentation and consistent communication are best practices in most areas of employment law. Combining these practices with accurate overtime calculations under the FLSA’s piece-rate formula led to a win here. If your company uses piece-rate compensation, take a moment to review your offer letters, paystubs, and onboarding practices because when the next dispute arrives, you’ll want your turkeys in a row.