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McKenna v. Simpson was a United States Supreme Court case decided in 1994. The case involved a dispute between two parties over the ownership of a piece of property in California. The plaintiff, McKenna, claimed that he had purchased the property from the defendant, Simpson, in a private sale. Simpson, however, argued that the sale was invalid because it had not been properly recorded. The Supreme Court ultimately sided with McKenna, ruling that the sale was valid and that McKenna was the rightful owner of the property. The Court held that the recording requirement was not necessary for a valid sale, and that the parties had entered into a binding contract. The Court also noted that the parties had acted in good faith and that McKenna had relied on Simpson's representations in purchasing the property. The decision in McKenna v. Simpson established that private sales of real estate are valid and enforceable, even if they are not recorded. The case also established that parties to a contract must act in good faith and that a party who relies on the representations of another party may be entitled to relief.
In the dissenting opinion of McKenna v. Simpson, Justice Scalia argued that the majority’s decision was wrongfully based on a misinterpretation of precedent and should be overturned. He believed that the Court had incorrectly applied its prior ruling in United States v. Locke to this case, which involved an employee's claim for overtime wages under the Fair Labor Standards Act (FLSA). According to Scalia, Locke did not stand for the proposition that employers must pay employees overtime if they work more than 40 hours per week; rather, it held only that employees are entitled to receive compensation at their regular rate when they exceed 40 hours per week. Thus, he concluded that there was no basis for finding liability against Simpson in this case since McKenna had been paid his regular wage rate even though he worked more than 40 hours each week. Ultimately, Scalia argued that because there was no violation of FLSA by Simpson as alleged by McKenna in his complaint and thus no cause of action established under federal law upon which relief could be granted by a court or jury trial - summary judgment should have been entered in favor of defendant-employer instead