In the case of Waialua Agricultural Co. v. Christian et al., 1938, the U.S Supreme Court was asked to determine whether certain activities performed by employees of a sugar plantation were considered agricultural labor and thus exempt from overtime pay under the Fair Labor Standards Act (FLSA). The workers in question were involved in cultivating and harvesting crops but also maintained irrigation ditches, roads, fences and buildings on the property. The court ruled that these maintenance tasks did not qualify as agricultural labor because they weren't directly related to farming operations but rather served general industrial purposes for the company's benefit. Therefore, those employees performing such duties should be eligible for overtime compensation according to FLSA regulations.

In the dissenting opinion for the case of Waialua Agricultural Co. v. Christian et al., Justice McReynolds disagreed with the majority's interpretation of what constitutes "agriculture" under the Fair Labor Standards Act (FLSA). He argued that workers involved in sugar production, even if they were not directly engaged in planting or harvesting crops, should still be considered agricultural laborers because their work was a necessary and integral part of agricultural operations. In his view, these workers were exempt from overtime pay requirements under FLSA as it was intended to cover only those employees who are engaged in commerce or in the production of goods for commerce but not those employed primarily on farms and plantations where their activities do not have such direct relation to interstate commerce. His interpretation emphasized a broader understanding of agriculture that includes all practices performed by a farmer or on a farm which are incidental to farming itself.