In the 1943 case Walling v. James V. Reuter, Inc., the U.S Supreme Court ruled that a business was subject to federal wage and hour laws if it had workers engaged in production for interstate commerce, even if those employees did not directly participate in such activities themselves. The court held that an employer could be considered as engaging in commerce under the Fair Labor Standards Act of 1938 (FLSA) even when its employees were not directly involved in producing goods for interstate trade but were essential to the overall operation of businesses which produced goods destined for other states. This ruling expanded FLSA's coverage by interpreting "engaged in commerce" broadly, thereby extending protections like minimum wage and overtime pay requirements to more workers.

In the dissenting opinion for Walling v. James V. Reuter, Inc., Justice Frank Murphy argued that the majority's interpretation of "production" under the Fair Labor Standards Act was too narrow and failed to consider Congress' intent when drafting this legislation. He contended that any activity contributing to commerce should be considered production, including activities such as maintenance work or repair services performed on machines used in manufacturing goods for interstate commerce. In his view, these activities are essential parts of a continuous production process and thus fall within the scope of federal wage regulations. By excluding them from coverage under FLSA, he believed it would undermine worker protections intended by Congress and create an unfair advantage for businesses seeking to evade compliance with minimum wage laws.