In the case of McLaughlin, Secretary of Labor v. Richland Shoe Co., 1987, the U.S. Supreme Court ruled that an employer's violation of the Fair Labor Standards Act (FLSA) must be willful for a three-year statute of limitations to apply instead of a two-year limit. The court held that "willfulness" requires proof that the employer either knew its conduct was prohibited by FLSA or showed reckless disregard for whether it was or not. In this particular case, Richland Shoe Company had misclassified some employees as exempt from overtime pay requirements and failed to keep accurate records over several years; however, there wasn't sufficient evidence to prove they did so willfully according to this definition. Therefore, only a two-year statute applied in their situation.

In the dissenting opinion for McLaughlin v. Richland Shoe Co., Justice Scalia argued that the majority's interpretation of "willful violations" under the Fair Labor Standards Act (FLSA) was too strict and inconsistent with Congress' intent. He believed that a violation should be considered willful if an employer knew or showed reckless disregard about whether its conduct was prohibited by FLSA, not only when it knowingly violated or acted in reckless disregard of the law itself as determined by the majority. This broader definition would better serve to deter employers from violating labor laws and protect employees' rights. Furthermore, he criticized how this stricter standard could potentially allow employers who were aware they might be breaking some law but did not know which specific one to escape liability for their actions.