Term: 2017
Docket: 16-1362
Encino Motorcars, Llc v. Navarro
- Pro
16-1362 ENCINO MOTORCARS, LLC V. NAVARRO DECISION BELOW: 845 F.3d 925 CERT. GRANTED 9/28/2017 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)(lO)(A). In its first decision in this case, the Ninth Circuit found Respondents non-exempt by deferring to a 2011 Department of Labor regulation. This Court granted certiorari, considered merits briefing and argument, and vacated that decision, holding that "§213(b)(10)(A) must be construed without placing controlling weight on the Department's 2011 regulation." Pet.App.44. On remand, the Ninth Circuit once again found Respondents non-exempt. As it had in its initial vacated decision, the Ninth Circuit acknowledged that its holding conflicts with published 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. Pet.App.30, 65. As it was last time around, the question presented is: Whether service advisors at car dealerships are exempt under 29 U.S.C. §213(b)(10)(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 2017 revolved around the interpretation of a provision under the Fair Labor Standards Act (FLSA) that exempts "any salesman, partsman or mechanic primarily engaged in selling or servicing automobiles" from overtime pay requirements. The dispute arose when service advisors at Encino Motorcars sued for back pay, arguing they were entitled to overtime compensation as their roles did not fall within this exemption. However, Encino Motorcars contended that these employees were indeed exempted because they sold services for cars. In a 5-4 decision favoring Encino Motorcars, the court ruled that service advisors are salesmen who are engaged in servicing automobiles and therefore qualify for FLSA's exemption from overtime pay requirements. The majority opinion stated that service advisors interact with customers and sell them services for their vehicles which makes them salesmen primarily engaged in servicing automobiles.
In the dissenting opinion for Encino Motorcars, LLC v. Navarro, Justice Ginsburg argued that service advisors at car dealerships should be entitled to overtime pay under the Fair Labor Standards Act (FLSA). She disagreed with the majority's interpretation of FLSA exemptions and contended that Congress intended to limit these exemptions narrowly. According to her view, service advisors are not salesmen who primarily engage in servicing automobiles; instead they sell services for cars. Therefore, she believed they do not fall within any exemption category and should receive overtime compensation when working more than 40 hours per week. Furthermore, she criticized the majority’s decision as it disregarded longstanding principles of statutory interpretation by failing to construe exceptions in FLSA narrowly and against their employer's interest.
