The U.S. Court of Appeals for the Fifth Circuit affirmed a lower court jury verdict that denied overtime compensation to Jerry Merritt, a former agency manager with Texas Farm Bureau and its affiliated insurance companies. The appellate court issued its decision on Feb. 6, 2026, in *Merritt v. Texas Farm Bureau*, case No. 24-50127.
Circuit Judge Stuart Kyle Duncan wrote the opinion for a three-judge panel that included Circuit Judges Haynes and Ramirez. The court held that Texas Farm Bureau had neither actual nor constructive knowledge of Merritt's overtime work, making the company not liable for additional compensation under federal overtime laws.
The case originated in 2019 when Merritt filed suit in the U.S. District Court for the Western District of Texas seeking overtime compensation for work performed during his employment as an Agency Manager. In that role, Merritt supervised teams of insurance agents across various Texas Farm Bureau agencies throughout the state.
Texas Farm Bureau operates through a collection of several insurance entities, including Texas Farm Bureau Casualty Insurance Company, Texas Farm Bureau Mutual Insurance Company, Texas Farm Bureau Business Corporation, Texas Farm Bureau Underwriters, Farm Bureau County Mutual Insurance Company of Texas, and Southern Farm Bureau Life Insurance Company. All of these entities were named as defendants in Merritt's lawsuit.
The case centered on whether Merritt was entitled to overtime pay under the Fair Labor Standards Act, the federal law that requires employers to pay time-and-a-half wages for work exceeding 40 hours per week. The key legal question was whether Texas Farm Bureau had knowledge that Merritt was working overtime hours.
After hearing evidence and arguments from both sides, a jury in the Western District of Texas found that Merritt was not entitled to overtime compensation. The jury determined that Texas Farm Bureau lacked both actual knowledge and constructive knowledge of any overtime work performed by Merritt during his employment.
Actual knowledge would require that the employer directly knew about the overtime work, while constructive knowledge means the employer should have known about the overtime work through reasonable supervision and monitoring of employee activities. The jury's finding that neither type of knowledge existed effectively cleared Texas Farm Bureau of liability.
Following the jury verdict, Merritt filed post-judgment motions with the district court seeking to overturn the jury's decision. The district court denied those motions, prompting Merritt to appeal to the Fifth Circuit.
On appeal, Merritt argued that the jury verdict was incorrect and that the evidence supported a finding that Texas Farm Bureau should have been aware of his overtime work. The case presented questions about employer obligations to monitor employee work hours and the standards for establishing knowledge of overtime work in supervisory positions.
The Fifth Circuit's decision to affirm the lower court ruling means that the jury verdict stands. Circuit Judge Duncan's opinion for the court concluded that the jury's findings were supported by the evidence and that the district court properly denied Merritt's post-trial motions.
The ruling has implications for similar overtime disputes involving supervisory employees and questions about employer knowledge of overtime work. The decision reinforces the principle that employees seeking overtime compensation must demonstrate that their employers had knowledge of the additional work hours.
For Texas Farm Bureau, the affirmance represents a victory in defending against overtime claims. The company successfully argued that it lacked sufficient knowledge of Merritt's claimed overtime work to trigger overtime pay obligations under federal law.
The case also highlights the challenges employees face in proving overtime claims, particularly when working in supervisory or management roles where work hours may be less closely monitored. The knowledge requirement creates a burden for employees to show that employers were aware of or should have been aware of overtime work.
The Fifth Circuit's jurisdiction covers Texas, Louisiana, and Mississippi, making this decision potentially influential for similar overtime disputes in those states. The ruling provides guidance for employers and employees regarding the knowledge standards that apply to overtime compensation claims.
The case file shows the litigation began with Merritt's original complaint filed in 2019 in the Western District of Texas under case number 6:19-CV-679. The case proceeded through discovery, trial, and post-trial motions before reaching the appellate level.
With the Fifth Circuit's affirmance, Merritt's options for further appeal are limited. He could potentially seek review by the Supreme Court, though the high court accepts only a small percentage of cases for review and typically focuses on cases involving significant legal questions or conflicts between circuit courts.
The decision concludes a multi-year legal battle between Merritt and Texas Farm Bureau over overtime compensation, with the appeals court ultimately siding with the employer's position that it lacked knowledge of the claimed overtime work.