Your Title Doesn’t Decide Your Overtime
“I’ve been called a manager since my first day. I never thought to ask what that title actually bought me.”
I hear some version of that sentence constantly.
Because a job title has never been the test.
California decides exempt status by what an employee actually does, hour to hour, not by what the offer letter calls the role. That is the entire premise behind Cortina v. North Am. Title Co., a case that took nineteen years, produced a $43 million judgment, and ended with the Court of Appeal reversing most of it. Not because the underlying wage claims were wrong on their face, but because of how the trial itself was run.
Here is the decoder version.
What the title says: “Manager.” “Officer.” “Supervisor.”
What that title actually means, by itself, under California wage law: nothing.
What decides it: whether the employee’s real, day-to-day duties meet the specific legal test for an exempt role, applied person by person, week by week, not department by department.
Cortina is not really a story about escrow officers. It is a story about how long a misclassification fight can take, and how much can turn on process rather than the paycheck itself. Nineteen years is not typical. The underlying question, whether the title matched the actual job, shows up in nearly every wage dispute I see, on a far shorter timeline.
Your title tells your employer what to call you. It does not tell a court whether the law considers you exempt.
Contact Michael Trust Law, APC for a no-charge initial consultation. The facts determine whether you have a claim — and how much of a conversation that takes.
This post shares general information based on common patterns I see in California workplaces. It is not legal advice, does not create an attorney-client relationship, and outcomes depend on specific facts — no lawyer can guarantee a result. Past results do not guarantee or predict future outcomes. AI may have been used to create this post. All content reviewed by a CA attorney before publication.