In the 1944 case Walling v. Youngerman-Reynolds Hardwood Co., Inc., the U.S. Supreme Court ruled on whether certain activities performed by employees before and after their regular work hours constituted "work" under the Fair Labor Standards Act (FLSA). The company, a hardwood manufacturer, required its workers to sharpen their tools and clean machinery outside of normal working hours without compensation. The Wage and Hour Division of the Department of Labor argued that these tasks were integral to job performance and should be compensated as such. The court agreed with this argument, ruling in favor of Walling (representing the Department) that these pre- or post-shift duties did indeed constitute work under FLSA guidelines because they were necessary for productive labor during paid working time. This decision established an important precedent regarding what constitutes compensable work time under federal law.

In the dissenting opinion for Walling v. Youngerman-Reynolds Hardwood Co., Inc., Justice Frank Murphy argued that the majority's interpretation of "produced" in the Fair Labor Standards Act was too narrow and failed to consider Congress' intent when drafting this legislation. He believed that Congress intended for a broad definition of production, one which would include any work directly essential to producing goods for commerce, such as maintaining or repairing machinery used in production. In his view, limiting coverage only to employees who were engaged in actual physical manufacturing undermined the law’s purpose: protecting all workers whose employment conditions affect interstate commerce from substandard labor conditions. By excluding maintenance workers from these protections, he feared it could create an unfair loophole allowing employers to exploit certain classes of workers without facing legal repercussions.