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Legally paying comp time instead of overtime is mostly restricted to state and local governmental employers We cannot tell from here. Ca has a limited comp time rule, but that is restricted to ca daily overtime only, and is narrowly worded.

New Overtime Rules in Effect January 2020 - Kramer, Elkins & Watt, LLC

If you google dol overtime settlement you can find hundreds of millions of dollars in settlements very quickly Past that, maybe your employer is a fool or maybe the employer is a knave Most of them were through the misuse of the outside sales exception (financial services, mortage industry and others), although other exempt exceptions have have been involved.

So one way or another, your employer is doing something wrong

Failing to give you a raise, however, is not it The above answer, whatever it is, assumes that no legally binding and enforceable contract or cba says otherwise. Or just home document violations, such as unpaid overtime When you eventually leave this employer, and you probably will, file a wage claim on your way out the door