This Ogletree, Deakins, Nash, Smoak & Stewart, P.C. memorandum discusses the California Supreme Court's December 29, 2011 decision in Harris v. The Superior Court of Los Angeles County, clarifying the administrative employee exemption. The state Supreme Court rejected the "administrative/production worker" dichotomy, holding that the proper test is a two-part test to determine if an employee's work is "directly related" to management policies or general business operations. California courts must consider whether the work is both qualitatively administrative and quantitatively "of substantial importance to the management or operations of business."