In the 1941 case Walling v. A.H. Belo Corporation, the U.S. Supreme Court dealt with issues related to wage and hour laws under the Fair Labor Standards Act of 1938 (FLSA). The Wage and Hour Division Administrator sued A.H. Belo Corporation, a newspaper company in Texas that paid its employees on a per-week basis regardless of hours worked rather than an hourly rate for overtime work as required by FLSA. The court ruled in favor of Walling, stating that employers must pay their workers at least one-and-a-half times their regular wages for any time worked beyond forty hours per week according to FLSA regulations. This decision reinforced federal labor standards ensuring fair compensation for overtime work.

In the dissenting opinion for Walling v. A.H. Belo Corporation, Justice Frank Murphy argued that the majority's decision undermined the purpose of the Fair Labor Standards Act (FLSA). He contended that by allowing employers to average out hours over several weeks rather than adhering to a strict 40-hour workweek, they were effectively permitting companies to circumvent overtime pay requirements and exploit workers. According to Justice Murphy, this interpretation was inconsistent with both the language and intent of FLSA – which he believed aimed at discouraging long working hours by making them costly for employers through mandatory overtime payments. Therefore, in his view, any system where an employer could avoid paying extra compensation for additional labor was fundamentally unfair and contrary to national policy as expressed in FLSA.