Encino Motorcars, LLC v. Navarro, et al.
Issues
Are individuals who are employed as “service advisors” at car dealerships subject to federal law governing over-time pay?
This case asks the Supreme Court to clarify whether automotive “service advisors” qualify for the Fair Labor Standards Act’s (“FLSA”) mandatory overtime pay requirements. Encino Motorcars, LLC, a Mercedes-Benz dealership in California, contends that these employees are primarily “servicem[e]n . . . engaged in . . . servicing automobiles” and thus they are clearly captured within the law’s exceptions. Similarly, Encino argues that even if the statute is sufficiently ambiguous on the matter, the Department of Labor’s interpretation of the statute is unreasonable and unentitled to judicial deference. Hector Navarro and other employees assert that construing the statute’s exception to include service advisors would violate the text, spirit, and purpose of the FLSA. Relatedly, they maintain that the Department’s interpretation is entirely reasonable and thereby warrants deference from the Court. The Supreme Court’s resolution of this case could affect the terms of employment between America’s 45,000 service advisors and their employers.
Questions as Framed for the Court by the Parties
Are “service advisors” at car dealerships exempt under 29 U.S.C. § 213(b)(10)(A) from the FLSA’s overtime-pay requirements?
Congress enacted the Fair Labor Standards Act (“FLSA”) in 1938, seeking to remedy perceived shortcomings in the national labor market and to provide a minimum standard of acceptable working conditions for all employees. See Brief for Petitioner, Encino Motorcars, LLC at 4–5. One provision of t