Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626 (7th Cir. 2010). · Go Syfert
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626 (7th Cir. 2010). Cases Citing This Book View Copy Cite
100 citation events (100 in the last 25 years) across 11 distinct courts.
Strongest positive: Justin Gibbs v. ABT Electronics, Inc. and Ricky Abt (ilnd, 2026-01-05)
Treatment trajectory · 2010 → 2026 · click a year to view as-of
2010 2018 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (rule) Justin Gibbs v. ABT Electronics, Inc. and Ricky Abt
N.D. Ill. · 2026 · confidence medium
P. 56(e)(2); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010). (“[A] district court may strictly enforce compliance with its local rules regarding summary judgment motions.”).
discussed Cited as authority (rule) Mayberry v. Schlarf
N.D. Ind. · 2025 · confidence medium
“While [Rule] 8(c) directs parties to raise affirmative defenses in the pleadings, a delay in raising an affirmative defense only results in waiver if the other party is prejudiced as a result.” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010) (citing Fed.
discussed Cited as authority (rule) Gibbs v. ABT Electronics, Inc.
N.D. Ill. · 2025 · confidence medium
L.R. 56.1(e)(3) (“Asserted facts may be deemed admitted if not controverted with specific citations to evidentiary material.”); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010). (“[A] district court may strictly enforce compliance with its local rules regarding summary judgment motions.”).
discussed Cited as authority (rule) Bureau of Consumer Financial Protection v. FDATR, Inc
N.D. Ill. · 2025 · confidence medium
L.R. 56.1(e)(3) (“Asserted facts may be deemed admitted if not controverted with specific citations to evidentiary material.”); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010). (“[A] district court may strictly enforce compliance with its local rules regarding summary judgment motions.”).
examined Cited as authority (rule) Noe v. Smart Mortgage Centers, Inc. (3×) also: Cited "see"
N.D. Ill. · 2024 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 631 (7th Cir. 2010).
discussed Cited as authority (rule) CALLAHAN v. MADISON COUNTY CORONER'S OFFICE
S.D. Ind. · 2023 · confidence medium
Once again, "[t]he burden is on the employer to prove that an employee is exempt under FLSA, and such exemptions are to be narrowly construed against the employer seeking the exemption." Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 631 (7th Cir. 2010) (internal citation omitted).
discussed Cited as authority (rule) Schaap v. Arcuri
N.D. Ind. · 2023 · confidence medium
Cf. Waldridge, 24 F.3d at 922 (sustaining summary judgment because the non-movant did not “make any effort to identify with specificity what factual issues were disputed, let alone supply the requisite citations to the evidentiary record”); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010), 969 F.3d at 349 (sustaining summary judgment because the “statement of facts did contain some pinpoint citations [but] did not directly respond to [the moving party’s] proposed findings and lumped several distinct factual assertions together in each paragraph”).
cited Cited as authority (rule) Michele Poland v. Springs Window Fashions, LLC
W.D. Wis. · 2022 · confidence medium
See, e.g., Verkuilen v. MediaBank, LLC, 646 F.3d 979, 981 (7th Cir. 2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 633 (7th Cir. 2010); Haywood v. N. Am.
discussed Cited as authority (rule) Loizon v. Evans (2×) also: Cited "see"
N.D. Ill. · 2022 · confidence medium
Under the Department of Labor (“DOL”) regulations in effect at the time Loizon was terminated, the executive exemption covers an employee: (1) [Who is] [c]ompensated on a salary basis at a rate not less than $455 per week; (2) Whose primary duty is management of the enterprise in which the employee is employed or of a customarily recognized department or subdivision thereof; (3) Who customarily and regularly directs the work of two or more other employees; and (4) Who has the authority to hire or fire other employees or whose suggestions and recommendations as to the hiring, firing, advanc…
discussed Cited as authority (rule) Walker v. Menards Inc.
N.D. Ill. · 2022 · confidence medium
See also Thornton v. M7 Aerospace LP, 796 F.3d 757, 769 (7th Cir. 2015)(“This court has repeatedly held that the district court is within its discretion to strictly enforce compliance with its local rules regarding summary-judgment....”); Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
cited Cited as authority (rule) Brown v. The Wheatleigh Corporation
D. Mass. · 2021 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010); Antiskay v. Contemporary Graphics and Bindery, Inc., Civil No. 11-7579 (NLH/KMW), 2013 WL 6858950 , at *7 (D.N.J.
cited Cited as authority (rule) Taysheedra Allen-Noll v. Madison Area Technical College
7th Cir. · 2020 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010); Hedrich v. Bd. of Regents of Univ. of Wis. Sys., 274 F.3d 1174, 1178 (7th Cir. 2001).
cited Cited as authority (rule) Taysheedra Allen-Noll v. Madison Area Technical College
7th Cir. · 2020 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010); Hedrich v. Bd. of Regents of Univ. of Wis. Sys., 274 F.3d 1174, 1178 (7th Cir. 2001).
cited Cited as authority (rule) Taysheedra Allen-Noll v. Madison Area Technical College
7th Cir. · 2020 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010); Hedrich v. Bd. of Regents of Univ. of Wis. Sys., 274 F.3d 1174, 1178 (7th Cir. 2001).
discussed Cited as authority (rule) Locascio v. Lend Lease (US) Construction, Inc.
N.D. Ill. · 2020 · confidence medium
See also Thornton v. M7 Aerospace LP, 796 F.3d 757, 769 (7th Cir. 2015)(“This court has repeatedly held that the district court is within its discretion to strictly enforce compliance with its local rules regarding summary-judgment . . . .”); Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
discussed Cited as authority (rule) Alnoraindus Burton v. Partha Ghosh
7th Cir. · 2020 · confidence medium
Global Tech‐ nology & Trading, Inc. v. Tech Mahindra Ltd., 789 F.3d 730 , 732 18 No. 19‐1360 (7th Cir. 2015), citing Williams v. Lampe, 399 F.3d 867, 871 (7th Cir. 2005), and Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010).
discussed Cited as authority (rule) Alnoraindus Burton v. Partha Ghosh
7th Cir. · 2020 · confidence medium
Global Tech‐ nology & Trading, Inc. v. Tech Mahindra Ltd., 789 F.3d 730 , 732 18 No. 19‐1360 (7th Cir. 2015), citing Williams v. Lampe, 399 F.3d 867, 871 (7th Cir. 2005), and Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010).
discussed Cited as authority (rule) Clews v. County of Schuylkill (2×) also: Cited "see, e.g."
M.D. Penn. · 2020 · confidence medium
(See Doc. 22.) See also Schmidt, 599 F.3d at 632 (finding that a party, who specifically raised an affirmative defense under the FLSA for the first time at summary judgment, did not waive it).
discussed Cited as authority (rule) ALERDING CASTOR HEWITT LLP v. FLETCHER
S.D. Ind. · 2020 · confidence medium
But the forfeiture rule is “not to be applied rigidly,” id., and a defense should be forfeited “only . . . if the other party is prejudiced,” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010); -accord Reed v. Columbia St.
discussed Cited as authority (rule) Long, Peter v. Heiser, Sandra
W.D. Wis. · 2019 · confidence medium
Int’l, Inc., 766 enforce compliance with its local rules regarding summary judgment motions.”); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630-31 (7th Cir. 2010) (holding that the district court did not err when it deemed the defendant’s proposed findings of fact admitted and refused to consider additional facts for the plaintiff’s failure to follow the local procedures on proposed findings of fact).
cited Cited as authority (rule) DAVIS v. MEDXCEL FACILITIES MANAGEMENT, LLC
S.D. Ind. · 2019 · confidence medium
See Corning Glass Works v. Brennan, 417 U.S. 188 , 196–97 (1974); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 631 (7th Cir. 2010).
discussed Cited as authority (rule) Self Barile v. Lutheran Health Network of Indiana, LLC
N.D. Ind. · 2019 · confidence medium
Thornton v. M7 Aerospace LP, 796 F.3d 757, 769 (7th Cir. 2015); Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
discussed Cited as authority (rule) Allen-Noll, Taysheedra v. Madison Area Technical College
W.D. Wis. · 2019 · confidence medium
Int’l, Inc., 766 F.3d 735, 737 (7th Cir. 2014) (“[T]his Circuit has routinely held that a district court may strictly enforce compliance with its local rules regarding summary judgment motions.”); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630-31 (7th Cir. 2010) (holding that the district court did not err when it deemed the defendant’s proposed findings of fact admitted and refused to consider additional facts for the plaintiff’s failure to follow the local procedures on proposed findings of fact).
discussed Cited as authority (rule) Jacks v. DirectSat USA, LLC. (2×) also: Cited "see"
N.D. Ill. · 2019 · confidence medium
As discussed in the text, defendants indirectly provide some of this information in their supporting memorandum. 4 Contrary to defendants’ contentions, Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010) does not hold that an answer’s denial of an allegation that the plaintiff was exempt preserves the defense.
discussed Cited as authority (rule) McCarty v. Menard, Inc.
N.D. Ill. · 2018 · confidence medium
Thornton v. M7 Aerospace LP, 796 F.3d 757, 769 (7th Cir. 2015); Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).2 But instead of deeming the defendant’s facts admitted, the court granted the plaintiff’s request to file a Rule-compliant response to Menards’ Statement of Uncontested Facts.
cited Cited as authority (rule) Terrance Mack v. City of Chicago
7th Cir. · 2018 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010).
cited Cited as authority (rule) Terrance Mack v. City of Chicago
7th Cir. · 2018 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010).
cited Cited as authority (rule) Terrance Mack v. City of Chicago
7th Cir. · 2018 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir. 2010).
cited Cited as authority (rule) Barrios v. Fashion Gallery, Inc.
N.D. Ill. · 2017 · confidence medium
Dist. 365U, 789 F.3d 707, 711 (7th Cir. 2015);Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir. 2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th.
cited Cited as authority (rule) Princeton Industrial, Products, Inc. v. Precision Metals Corp.
N.D. Ill. · 2015 · confidence medium
Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
cited Cited as authority (rule) Global Technology & Trading, Inc. v. Tech Mahindra Ltd.
7th Cir. · 2015 · confidence medium
See, e.g., Williams v. Lampe, 399 F.3d 867, 871 (7th Cir.2005); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir.2010).
discussed Cited as authority (rule) Deschepper v. Midwest Wine & Spirits, Inc.
N.D. Ill. · 2015 · confidence medium
An “outside salesperson” is “an employee (1) whose ‘primary duty’ consists of ‘making sales’ or ‘obtaining orders or contracts for services’ and (2) who is ‘customarily and regularly engaged away from the employ er’s place or places of business in performing such primary duty.” Schmidt v. Eagle Waste & Recycling, 599 F.3d 626, 631 (7th Cir.2010) (quoting 29 C.F.R. § 541.500 ).
cited Cited as authority (rule) Grabianski v. Bally Total Fitness Holding Corp.
N.D. Ill. · 2015 · confidence medium
Wiegel v. Stork Craft Mfg., Inc., 946 F.Supp.2d 804, 809 (N.D.Ill.2013) (citing Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010)).
discussed Cited as authority (rule) Wilkins v. Just Energy Group, Inc.
N.D. Ill. · 2015 · confidence medium
In contrast, in an FLSA case about the “outside salesperson” exemption, the Seventh Circuit held that “[t]he burden is on the employer to prove that an employee is exempt under FLSA, and such exemptions are to be narrowly construed against the employer seeking the exemption.” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 631 (7th Cir.2010) (internal citation omitted); see also Meacham v. Knolls Atomic Power Lab., 554 U.S. 84, 93 , 128 S.Ct. 2395 , 171 L.Ed.2d 283 (2008) (as a “general rule,” the employer bears the burden of proof when claiming that a FLSA exemption applie…
discussed Cited as authority (rule) Trout v. Village of Westmont
N.D. Ill. · 2014 · confidence medium
The burden falls on the employer to prove that an employee is exempt under FLSA, see Schaefer-LaRose v. Eli Lilly & Co., 679 F.3d 560, 574 (7th Cir.2012); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 628 (7th Cir.2010), and such exemptions are to be narrowly construed against the employer seeking the exemption.
cited Cited as authority (rule) Mickelson v. Mickelson
7th Cir. · 2014 · confidence medium
L.R. 56.2; Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630-31 (7th Cir.2010); Salvadori v. Franklin Sch.
cited Cited as authority (rule) Abraham v. Washington Group International, Inc.
7th Cir. · 2014 · confidence medium
Schmidt v. Eagle Waste and Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
cited Cited as authority (rule) Crayton v. Cook County Correctional Officer Graffeo
N.D. Ill. · 2014 · confidence medium
Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
discussed Cited as authority (rule) Wiegel v. Stork Craft Manufacturing, Inc.
N.D. Ill. · 2013 · confidence medium
The purpose of the rule-with which district courts in this circuit are entitled to require strict compliance, Patterson v. Indiana Newspapers Inc., 589 F.3d 357, 360 (7th Cir.2009)—is to “ensur[e] that the proposed findings of fact are in a form that permits the district court to analyze the admissible evidence supporting particular factual propositions and determine precisely what facts, if any, are material and disputed.” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
cited Cited as authority (rule) Nelson v. Santander Consumer USA, Inc.
W.D. Wis. · 2013 · confidence medium
Generally, “a delay in raising an affirmative defense only results in waiver if the other party is prejudiced as a result.” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir.2010).
discussed Cited as authority (rule) Holleman v. Penfold
7th Cir. · 2013 · confidence medium
Because Holleman received notice that failing to provide proper citations could lead to the admission of the defendants’ version of the facts, see Outlaw v. Newkirk, 259 F.3d 833, 841-42 (7th Cir.2001); Houston v. Sidley & Austin, 185 F.3d 837 , 838 n. 1 (7th Cir.1999), the district court was entitled to require strict compliance with its local rules, see, e.g., McNeil v. United States, 508 U.S. 106, 113 , 113 S.Ct. 1980 , 124 L.Ed.2d 21 (1993); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630-31 (7th Cir.2010); Cady v. Sheahan, 467 F.3d 1057, 1061 (7th Cir.2006).
cited Cited as authority (rule) Jermain King v. Don Schieferrdecker
7th Cir. · 2012 · confidence medium
See Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir. 2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir. 2010).
cited Cited as authority (rule) King v. Schieferdecker
7th Cir. · 2012 · confidence medium
See Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
cited Cited as authority (rule) Ebrahime v. Dart
N.D. Ill. · 2012 · confidence medium
Yancick v. Hanna Steel Corp., 653 F.3d 532, 537 (7th Cir.2011); Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
discussed Cited as authority (rule) Yancick v. Hanna Steel Corp.
7th Cir. · 2011 · confidence medium
This court has “routinely held that a district court may strictly enforce compliance with its local rules regarding summary judgment motions.” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630 (7th Cir.2010).
cited Cited as authority (rule) Coleman v. Goodwill Industries of Southeastern Wisconsin, Inc.
7th Cir. · 2011 · confidence medium
Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 630-31 (7th Cir.2010).
discussed Cited as authority (rule) Ahle v. Veracity Research Co.
D. Minnesota · 2010 · confidence medium
In support of its position, Veracity cites Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 632 (7th Cir.2010), and Hunter v. Sprint Corp., 453 F.Supp.2d 44 , 51 n. 3 (D.D.C.2006), both of which rejected the argument that an employer waived the right to assert specific exemption defenses when its answer pleaded only the general assertion that the employees were exempt.
discussed Cited as authority (rule) Jirak v. Abbott Laboratories, Inc.
N.D. Ill. · 2010 · confidence medium
“The burden is on the employer to prove that an employee is exempt under FLSA, and such exemptions are to be narrowly construed against the employer seeking the exemption.” Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626, 631 (7th Cir.2010) (citations omitted).
discussed Cited "see" Continental 611 Fund LLC v. Certain Underwriters at Lloyds London, et al.
E.D. Wis. · 2025 · signal: see · confidence high
See Schmidt v. Eagle Waste & Recycling, Inc., 599 F.3d 626 , 631 n.2 (7th Cir. 2010) (observing that granting leave to file a sur-reply is within the district court’s discretion); Groshek v. Time Warner Cable, Inc., Case No. 15–C–157, 2016 WL 4203506 , at *4 (E.D.
discussed Cited "see" Over v. English
E.D. Wis. · 2025 · signal: see · confidence high
See Schmidt v. Eagle Waste & Recycling Inc., 599 F.3d 626 (7th Cir. 2010) noting that the Seventh Circuit has “routinely held that a district court may strictly enforce compliance with its local rules regarding summary judgment motions.”); see Phoneprasith v. Greff, No. 21-3069, 2022 WL 1819043 (7th Cir. June 3, 2022) (holding that a district court is entitled to deem unopposed facts admitted under Civ.
Retrieving the full opinion text from the archive…
Tammy SCHMIDT, Plaintiff-Appellant,
v.
EAGLE WASTE & RECYCLING, INC., Defendant-Appellee
09-1901.
Court of Appeals for the Seventh Circuit.
Mar 22, 2010.
599 F.3d 626
Samuel C. Gold (argued), Tallahassee, FL, for Plaintiff-Appellant., Geoffrey S. Trotier (argued), Davis & Kuelthau, Milwaukee, WI, for Defendant Appellant.
Posner, Flaum, Sykes.
Cited by 86 opinions  |  Published
2 passages pin-cited by 2 cases
Pinpoint authority: bottom 76%
Citer courts: N.D. Illinois (2)
FLAUM, Circuit Judge.

The plaintiff, Tammy Schmidt, brought this action for monetary relief under the Fair Labor Standards Act (“FLSA”), alleging that she was not paid overtime due under the Act. The defendant, Eagle Waste and Recycling, Inc. (“Eagle”), moved for summary judgment, arguing that Schmidt was exempt from the act because she was either an “outside salesperson” or a combination of an “outside salesperson” and an “administrative employee.” Taking Eagle’s proposed findings of fact as true because Schmidt failed to contest them in the manner prescribed by the local rules, the district court granted summary judgment for the defendant. Schmidt appeals, arguing that the district court erroneously denied her an opportunity to cure the defects in her response brief, failed to “liberally construe” the FLSA, and incorrectly applied the “outside salesperson” and “combination” exemptions to the FLSA. We affirm.

I. Background [1]

Eagle, a corporation located in Eagle River, Wisconsin, is in the business of waste removal from residential and commercial properties. Alan Albee is the president of Eagle and has been since its founding on July 1, 2005. Albee hired Schmidt on September 12, 2005. According to Eagle, Schmidt was hired as a sales representative and adopted the title of “account representative” with Albee’s permission.[*629] Schmidt reported to Albee, her sole supervisor.

Schmidt’s duties included contacting potential commercial customers at their places of business and convincing them to use Eagle’s waste disposal and recycling services. She was responsible for bringing in new customers, and maintaining and increasing the business of existing customers. Schmidt spent some time in the office on approximately half of her workdays. On those days, she was in the office between one and four hours. Schmidt spent four to eight hours a day outside the office making sales calls to current and potential customers. Schmidt would schedule in-person sales calls in the mornings and afternoons so that she could meet with these customers on the way to and from the office. She controlled the amount of time she spent on these calls. She was also authorized to negotiate prices with customers. For her efforts, she was paid a commission on sales in addition to her base salary.

Schmidt also had promotional and marketing duties. She conferred frequently with Albee to determine new locations and businesses to target. Schmidt would then develop a marketing campaign that Albee would review. Schmidt spent time in and out of the office promoting Eagle. For example, she attended weekly chamber of commerce meetings and social functions, where she distributed business cards and flyers, talked to area business people, and sold services Eagle offered. Schmidt spent approximately five or six hours a week promoting Eagle outside the office, including two to four hours a week at chamber of commerce meetings. She spent another ten hours a week working on promotional and marketing efforts at the office.

Finally, Schmidt was responsible for customer service and maintaining the customer database. She made in-person visits to resolve any service problems her customers had, ranging from confusion with neighbors’ containers to billing and accounting. Her database tracked current customers, prospects, and lost customers. She used the database to collect money owed by her customers, sometimes adjusting bills if a customer had a complaint or concern. These collections formed the basis of her commission payments.

Occasionally, other employees consulted Schmidt when Albee was out of the office. For example, if a customer complained about service, Schmidt would decide whether to give the customer a credit on the next bill. If a vehicle needed to be repaired, Schmidt would sometimes authorize the ordering of replacement parts without consulting Albee.

When she was hired in September 2005, Schmidt’s base salary was $384.62 a week plus commission. Beginning January 1, 2006, she received a base salary of $461.54 a week plus commission. She received $26,319.75 in commissions during her time as an employee of Eagle, which ended on December 31, 2007.

Schmidt brought this action in state court on April 4, 2008. Eagle removed the case to federal court and answered the complaint on April 23, 2008. On May 15, 2008, Magistrate Judge Stephen Crocker held a pretrial conference in which he set deadlines for discovery and a trial date. Notice of these deadlines was sent to both parties along with a copy of the procedures for briefing summary judgment motions. Following depositions of Schmidt and Albee, Eagle filed its motion for summary judgment on November 13, 2008. Schmidt filed her brief in opposition to Eagle’s motion on December 4, 2008, before the deadline of December 15, 2008. That same day, she filed a sworn affidavit making various statements in support of her[*630] response. Eagle filed its reply on December 12, 2008, raising Schmidt’s failure to respond to its proposed findings of fact in accordance with the local rule and asking that Schmidt’s affidavit be stricken because it contradicted her deposition testimony. On December 26, 2008, Schmidt filed a motion for leave to file a sur-reply brief and to modify her responses to Eagle’s proposed findings of fact. The brief and proposed findings of fact she sought to file were not included with the motion.

On February 25, 2009, the district court entered an order denying Schmidt’s motion for leave to file a surreply brief and correct her proposed findings of facts. The same order granted summary judgment to Eagle. Schmidt now appeals.

II. Analysis

At the outset, we must address Schmidt’s argument that the district court erred when it deemed Eagle’s proposed findings of fact admitted and refused to consider additional facts alleged by Schmidt. The district court did so because Schmidt failed to follow the local rule for making and opposing proposed findings of fact for summary judgment, which required her to respond to the defendant’s proposed findings paragraph by paragraph and put her own proposed findings into separate numbered paragraphs. Instead, Schmidt included only a “statement of facts” of the sort that might be found in an appellate brief. While this statement of facts did contain some pinpoint citations, it did not directly respond to Eagle’s proposed findings and lumped several distinct factual assertions together in each paragraph.

We have routinely held that a district court may strictly enforce compliance with its local rules regarding summary judgment motions. See, e.g., Patterson v. Indiana Newspapers Inc., 589 F.3d 357, 360 (7th Cir.2009). Indeed, we have previously upheld a district court’s decision to enforce compliance with the precise local rule at issue here. See Hedrich v. Bd. of Regents of Univ. of Wis. Sys., 274 F.3d 1174, 1177 (7th Cir.2001). In Hedrich, as here, the nonmoving party did include some citations to the record but failed to follow the requirement that specific factual allegations be made or contested in numbered paragraphs. Id. at 1178. Similarly, as in Hedrich, a separate reminder of the local rule accompanied notices sent to the parties. Id. Schmidt’s reliance on a pair of Supreme Court cases addressing pleading standards, Swierkiewicz v. Sorema N.A., 534 U.S. 506, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002) and Conley v. Gibson, 355 U.S. 41, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957), is misplaced. Not only has Conley been abrogated by Bell Atlantic v. Twombly, 550 U.S. 544, 560-63, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007), but the issue of notice pleading is fundamentally different from compliance with the local rule at issue here. The local rule serves an important function by ensuring that the proposed findings of fact are in a form that permits the district court to analyze the admissible evidence supporting particular factual propositions and determine precisely what facts, if any, are material and disputed. See Hedrich, 274 F.3d at 1178. This is not a hyper-technical rule that turns “pleading [into] a game of skill in which one misstep by counsel may be decisive of the outcome,” Conley, 355 U.S. at 48, 78 S.Ct. 99. Rather, the rule provides district courts with the means to resolve motions for summary judgment on the merits. Here, even after Schmidt was informed of the deficiencies in her response brief, she waited two weeks before asking for leave to correct her proposed findings of fact and did not tender a corrected version with her motion. The district court concluded that Schmidt had not given an adequate expía[*631] nation for her disregard of the local rules or her delay in attempting to cure the error. Schmidt has not explained why those findings were erroneous. Consequently, the district court did not abuse its discretion when it denied Schmidt the opportunity to amend her response brief and proposed findings of fact. [2] We therefore proceed, as the district court did, on the findings of fact proposed by Eagle.

Next, we address Schmidt’s argument that she was not an “outside salesperson” as defined in the FLSA regulations. The Secretary of Labor defines an “outside salesperson” as an employee (1) whose “primary duty” consists of “making sales” or “obtaining orders or contracts for services” and (2) who is “customarily and regularly engaged away from the employer’s place or places of business in performing such primary duty.” 29 C.F.R. § 541.500 (2009). An employee’s “primary duty” is the “principal, main, major, or most important duty that the employee performs.” Id. § 541.700. Time spent performing exempt work is useful, but not dispositive, in determining an employee’s primary duty. Id. The burden is on the employer to prove that an employee is exempt under FLSA, see Piscione v. Ernst & Young LLP, 171 F.3d 527, 533 (7th Cir.1999), and such exemptions are to be narrowly construed against the employer seeking the exemption. See Yi v. Sterling Collision Centers, Inc., 480 F.3d 505 (7th Cir .2007).

While Schmidt argues that the district court failed to “liberally construe” FLSA in her favor, the district court identified the correct legal standard and applied it to the facts before the court. The undisputed facts show that Schmidt’s primary duty was outside sales. On average, Schmidt spent four to eight hours a day outside the office making in-person sales calls. She visited the office on only about half of her workdays. At the office, much of her work furthered her efforts to make sales. She maintained a database of her customers, which formed the basis of her collections and commission payments. This sort of work relates directly to her outside sales work and is thus exempt itself. See 29 C.F.R. § 541.703 (2009). She also spent about ten hours a week developing marketing plans and doing other promotional work inside the office, and five to six hours a week promoting Eagle outside of the office. Other than Albee, Eagle’s president, who made some sales directly, there do not appear to have been any other Eagle employees directly involved in sales work. Most of the fruits of Schmidt’s promotional work were therefore realized through her own sales. Thus, this promotional work also counts as exempt outside sales work. See id. § 541.503(a) (promotional work is exempt if it is “incidental to and in conjunction with an employee’s own outside sales or solicitations” but nonexempt if it “is incidental to sales made, or to be made, by someone else”).

We also agree with the district court that even if Schmidt did not qualify for the outside salesperson exemption on its own, she would fall within the “combination exemption” to the FLSA. Employees “who perform a combination of exempt duties as set forth in the regulations in this part for[*632] ... administrative [and] outside sales ... employees may qualify for exemption.” 29 C.F.R. § 541.708 (2009). Eagle argues that to the extent Schmidt performed duties unrelated to outside sales, these were largely exempt “administrative” duties. See id. § 541.200.

Before we proceed to the merits of Eagle’s argument, however, we must address Schmidt’s claim that Eagle has waived any reliance on the combination exemption. Schmidt argues that the combination exemption is an affirmative defense that should have been raised in Eagle’s answer. [3] She also argues that, in response to a request to admit, Eagle admitted that Schmidt was not an administrative employee. Schmidt made these arguments, which she frames as an issue of “estoppel,” to the district court on summary judgment, but the district court did not mention waiver or estoppel in its opinion granting summary judgment.

While Fed.R.Civ.P. 8(c) directs parties to raise affirmative defenses in the pleadings, a delay in raising an affirmative defense only results in waiver if the other party is prejudiced as a result. See Curtis v. Timberlake, 436 F.3d 709, 711 (7th Cir. 2005). Eagle did not raise the administrative or combination exemptions explicitly in its answer. It did, however, deny that Schmidt was a covered employee under FLSA and deny that Schmidt was a nonexempt employee. The nature of Schmidt’s work was the primary focus of the depositions of Albee and Schmidt. Schmidt argues that Eagle misled her by denying in discovery that she was an “administrator” as defined in the FLSA regulations. But the request to admit was itself misleading' — “administrator” is defined only as the Administrator of the Wage and Hour Division. See 29 C.F.R. § 541.1 (2009). Although it seems unlikely that Eagle’s counsel thought Schmidt was asking them to admit that she was the Administrator of the Wage and Hour Division, rather than inartfully asking if Eagle intended to invoke the administrative exemption, Eagle’s response was literally true and the confusion, if any, stems from Schmidt’s vague request to admit. In any event, Eagle’s consistent position that Schmidt was an exempt employee and the course of discovery as a whole should have put Schmidt on notice that the administrative and combination exemptions were at issue. Eagle raised the combination and administrative exemptions in its opening brief on summary judgment and Schmidt argued them on the merits in her response brief. Because Schmidt has not shown any prejudice from Eagle’s delay in raising the administrative and combination exemptions to FLSA, the district court did not abuse its discretion in reaching the merits. Curtis, 436 F.3d at 711.

We agree with the district court that to the extent Schmidt’s work was not related to outside sales, it was primarily exempt administrative work. The administrative employee exemption applies to any employee who is:

(1) Compensated on a salary or fee basis at a rate of not less than $455 per week ...;
(2) Whose primary duty is the performance of office or non-manual work directly related to the management or general business operations of the employer or the employer’s customers; and
(3) Whose primary duty includes the exercise of discretion and independent judgment with respect to matters of significance.

[*633] 29 C.F.R. § 541.200 (2009). With the exception of her first few months of employment, Schmidt’s base salary exceeded the $455 per week minimum. [4] When Schmidt was not actively pursuing sales, she developed advertising and marketing plans, managed customer complaints, administered the customer database, and dealt with issues that would have been handled by Albee had he been in the office, such as approving an order of parts for broken machinery. This office work was directly related to the management and general business operations of Eagle. See id. § 541.201 (“Work directly related to management or general business operations includes, but is not limited to, work in functional areas such as ... purchasing; procurement; advertising; marketing; research; ... personnel management; ... public relations; ... database administration; ... and similar activities.”); see also Haywood v. North American Van Lines, Inc., 121 F.3d 1066, 1067-68 (7th Cir.1997) (finding customer service coordinator for shipping company to be an exempt administrative employee). While Schmidt argues that Albee “micromanaged” her work, the undisputed facts show that she negotiated with customers over price and service credits, created marketing campaigns, placed advertisements, collected from accounts, and set her own schedule. Cf. Haywood, 121 F.3d at 1072 (holding that resolving customer complaints and disputes about billing requires the exercise of discretion and independent judgment). Thus, the district court did not err by holding that even if Schmidt’s primary duty was not outside sales, the combination of her outside sales and administrative work exempts her from the FLSA’s overtime requirements.

III. Conclusion

We AFFIRM the district court’s grant of summary judgment to Eagle.

1

. This summary of the undisputed facts comes mainly from the district court's opinion, which is in turn largely based on Eagle's proposed findings of undisputed fact. We address Schmidt’s argument that this summary unfairly deems those findings admitted in Part II of this opinion.

2

. Schmidt also sought leave to file a sur-reply on the “sham affidavit rule,” which Eagle had raised in its reply brief to attack an affidavit filed by Schmidt along with her response brief. The district court denied Schmidt leave to file a sur-reply and instead decided the summary judgment motion without reference to Eagle's sham affidavit rule argument. Because this was the only new argument raised in Eagle's reply brief and the district court did not rely on it, the district court did not abuse its discretion when it denied Schmidt's request for leave to file a sur-reply.

3

. Eagle did not raise the outside salesperson defense in its answer, either. Schmidt, however, does not argue that Eagle has waived that defense.

4

. The record reflects only the total of Schmidt's commission payments. Spread over the course of her employment, she received an average of $225 per week in corn-mission. Thus, even Schmidt’s lower weekly salary of $384 exceeded the $455 minimum when combined with her commission payments.