Encino Motorcars, LLC v. Navarro
Issues
Are service advisors at car dealerships exempt from the Fair Labor Standard Act’s overtime-pay requirements under 29 U.S.C. § 213(b)(10)(A)?
The issue in this case involves whether the Fair Labor Standards Act’s (“FLSA”) overtime-pay exemption for “any salesman, partsman, or mechanic primarily engaged in selling or servicing automobiles,” contained in 29 U.S.C. § 213(b)(10)(A), also exempts service advisors. Encino Motorcars argues that the plain language and structure of § 213(b)(10)(A) unambiguously exempt service advisors from the FLSA’s overtime requirements. Navarro argues that the plain language and structure of § 213(b)(10)(A) clearly do not exempt service advisors from the FLSA’s overtime requirements and that Congress’s intent in enacting the exemption and the FLSA as a whole support this interpretation. From a policy perspective, this case is significant because a decision favoring Navarro could force dealerships across the United States to alter their payment systems for service advisors, of which there are around 100,000. Such an outcome could also expose dealerships to retroactive liability and back-pay in order to settle FLSA claims concerning overtime.
Questions as Framed for the Court by the Parties
Whether service advisors at car dealerships are exempt under 29 U.S.C. § 213(b)(10)(A) from the Fair Labor Standards Act's overtime-pay requirements.
In 2012, a group of five individuals employed as service advisors (collectively “Navarro”) at Encino Motorcars (“Encino”) filed suit against Encino for violating the Fair Labor Standards Act (“FLSA”) by, among other things, failing to pay them overtime wages.
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Additional Resources
- Jay-Anne B. Casuga, Mercedes Dealer Overtime Case Again Gets SCOTUS Review, Bloomberg BNA (Sept. 28, 2017).
- John Kennedy, FLSA Exemption Case Returns to Supreme Court, Law 360 (Sept. 28, 2017).