Term: 2015
Docket: 15-415
Encino Motorcars, Llc v. Navarro
- Pro
15-415 ENCINO MOTORCARS, LLC V. NAVARRO DECISION BELOW: 780 F.3d 1267 CERT. GRANTED 1/15/2016 QUESTION PRESENTED: Respondents are "service advisors" at a car dealership whose primary job responsibilities involve identifying service needs and selling service solutions to the dealership's customers. Respondents brought suit against the dealership under the Fair Labor Standards Act (FLSA), 29 U.S.C. §§201-219, seeking time-and-a-half overtime pay for working more than 40 hours per week. The FLSA exempts from its overtime requirements "any salesman, partsman, or mechanic primarily engaged in selling or servicing automobiles." Id. §213(b)(10)(A). Relying on an unbroken line of authority from other jurisdictions, the district court dismissed Respondents' claims, concluding that a service advisor is a "salesman . . . engaged in ... servicing automobiles" and is thus exempt from the FLSA's overtime requirements. The Ninth Circuit reversed, deferring to a Department of Labor interpretive regulation stating that service advisors are not exempt under §213(b)(10)(A) because they do not personally service automobiles. The Ninth Circuit readily acknowledged that its holding "conflicts with decisions of the Fourth and Fifth Circuits, several district courts, and the Supreme Court of Montana," all of which hold that service advisors are exempt employees. Pet.App.11. The question presented is whether "service advisors" at car dealerships are exempt under 29 U.S.C. §213(b)(lO)(A) from the FLSA's overtime-pay requirements. LOWER COURT CASE NUMBER: 13-55323
The U.S. Supreme Court case Encino Motorcars, LLC v. Navarro in 2015 revolved around the issue of whether service advisors at car dealerships are entitled to overtime pay under the Fair Labor Standards Act (FLSA). The FLSA requires employers to pay employees one-and-a-half times their regular wage for any hours worked beyond a standard 40-hour work week, but it also includes several exemptions - including "any salesman...primarily engaged in selling or servicing automobiles." Service advisors argued that they were not covered by this exemption and thus deserved overtime pay. Initially, the Ninth Circuit Court sided with the service advisors based on an interpretation of Department of Labor regulations. However, upon appeal to the Supreme Court, it was ruled that these regulations were issued without adequate explanation and therefore should not be given deference; hence remanding back down for reconsideration without relying on those rules.
In the dissenting opinion for Encino Motorcars, LLC v. Navarro, Justice Ginsburg argued that service advisors should be entitled to overtime pay under the Fair Labor Standards Act (FLSA). She disagreed with the majority's interpretation of "salesman" and believed it was too narrow. According to her view, a salesman is anyone who sells goods or services - not just those who sell vehicles. As such, she contended that service advisors are salesmen because they sell customers on repair and maintenance services for their cars. Furthermore, she pointed out that Congress did not explicitly exclude service advisors from FLSA protections when it amended the statute in 1974; instead, lawmakers only excluded certain types of mechanical workers involved in selling or servicing automobiles. Therefore, according to Justice Ginsburg’s interpretation of legislative intent and statutory language within its broader context rather than isolated phrases or words alone led her to conclude that service advisers were indeed covered by FLSA overtime provisions.
