In the case of Idaho Sheet Metal Works, Inc. v. Wirtz, Secretary of Labor (1965), the U.S. Supreme Court was asked to determine whether employees who were engaged in activities related to agriculture but not directly involved in farming operations could be exempt from wage and hour provisions under the Fair Labor Standards Act (FLSA). The dispute arose when a company that manufactured items such as sprinkler systems for farms argued its workers should be classified as agricultural laborers and thus exempt from FLSA requirements. However, the court ruled against this interpretation stating that only those employees who are directly engaged in primary farming operations or secondary farming practices performed by a farmer on his own farm can qualify for an exemption under FLSA's definition of "agriculture". Therefore, manufacturing work done off-site did not fall within these categories even if it was used in agricultural processes.

In the dissenting opinion for Idaho Sheet Metal Works, Inc. v. Wirtz, Justice Harlan disagreed with the majority's interpretation of the Fair Labor Standards Act (FLSA). He argued that Congress did not intend to include all employees in an enterprise under FLSA coverage simply because some parts of it affected interstate commerce. Instead, he believed that only those employees directly involved in such activities should be covered by federal wage and hour laws. Furthermore, he contended that this broad interpretation could lead to unnecessary federal intervention into local businesses and industries which were traditionally regulated by states or localities themselves. Thus, according to him, a more restrictive reading was necessary to avoid potential overreach on part of the Federal Government into areas where its involvement may not have been intended or desirable.