In the 1945 case of Roland Electrical Co. v. Walling, Wage and Hour Administrator, the U.S Supreme Court ruled on whether or not employees who were engaged in producing goods for interstate commerce fell under the Fair Labor Standards Act (FLSA) of 1938. The Roland Electrical Company argued that its workers did not fall under this category as they only produced a small percentage of products intended for interstate commerce while most were used within their home state. However, the court disagreed with this argument stating that even if a minor portion was involved in interstate commerce it would still be covered by FLSA regulations which mandate minimum wage and overtime pay standards among other things. Thus, ruling against Roland Electrical Company's claim to exempt itself from these federal labor laws based on its predominantly intrastate business operations.

In the dissenting opinion for Roland Electrical Co. v. Walling, Justice Frankfurter argued that the majority's interpretation of "production" under the Fair Labor Standards Act was too broad and failed to consider Congress' intent when drafting the legislation. He contended that not all activities carried out by a company should be considered production, especially if they are only indirectly related to goods produced for commerce. In this case, he believed that employees who were engaged in maintaining and repairing equipment used in producing goods did not fall within the scope of “production” as defined by FLSA because their work was incidental rather than integral to actual production processes. Therefore, these workers should not be entitled to overtime pay under federal law according to him.