Supreme Court Rejects Notion That FLSA Exemptions Should Be “Narrowly Construed”

1 Minute Read

April 5, 2018

Categories: Employment Policies, Supreme Court Cases

A single paragraph in an otherwise routine opinion could have reverberations in FLSA exemption cases for years to come.

Earlier this week, in a 5-4 decision, the Supreme Court held in Encino Motorcars LLC v. Navarro et al. that auto service advisors are exempt under the FLSA’s overtime pay requirement. While the case resolved a circuit split for a discrete exemption, the Court’s decision has broad implications for all employers.

In examining the exemption, the Court rejected the longstanding principle that FLSA exemptions should be “narrowly construed.” The Court stated that the narrow construction principle “relies on the flawed premise that the FLSA ‘pursues’ its remedial purpose ‘at all costs.’”

Instead, the Court held that FLSA exemptions should be given a “fair reading.” The Court’s rationale was based on the fact that the FLSA gives no “textual indication” that exemptions should be narrowly construed.

Justice Ginsburg’s dissent noted that the majority’s decision “unsettles more than half a century of our precedent.”

The Court’s “fair reading” analysis will undoubtedly be beneficial for employers arguing for a broader interpretation of other FLSA exemptions.

Tags: Encino Motorcars, FLSA, Supreme Court

Ryan M. Bates
Partner
+1 202 955 1596
Email | vCard | Bio | Posts
Ryan has distinguished himself as a nationwide litigator handling complex employment litigation, trade secret cases, and other high-stakes litigation. Ryan has litigated cases in the state and federal courts of 25 states. He has ...
Michael Reed
Counsel
+1 713 229 5719
Email | vCard | Bio | Posts
Michael represents corporate clients in all manner of labor and employment matters, including non-compete and trade secret litigation, wrongful termination, wage and hour disputes, and union organizing. Michael also advises ...

You May Also Be Interested In

3 Minute Read

March 16, 2026

Trends in Employment Litigation Filings: Retailers Take Notice

By Daniel J. Butler and Robert T. Quackenboss

The results are in: attorneys are filing more employment law cases in court. Indeed, year-end reporting from legal databases like LexMachina confirm that the pace of filing new employment discrimination cases reached its highest level in 2025, surpassing 20,000 new filings nationwide. Though overtime and minimum wage lawsuits under the Fair Labor Standards Act (FLSA) have continued to decline since 2015, discrimination cases under laws like Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act are on the rise.

1 Minute Read

November 24, 2025

The FTC is Reduced to Two Commissioners with Melissa Holyoak’s Resignation

On November 17, 2025, the Federal Trade Commission announced that Commissioner Melissa Holyoak has resigned her post, bringing the total number of vacant commissioner seats to three.

4 Minute Read

October 15, 2025

Seventh Circuit Rejects Lenient Two-Step “Lusardi” Standard for FLSA/ADEA Collective Action Notice

By Katherine P. Deegan

The Seventh Circuit Court of Appeals recently issued a significant ruling for employers facing Fair Labor Standards Act (FLSA) and Age Discrimination in Employment Act (ADEA) collective actions.

2 Minute Read

September 25, 2025

U.S. Supreme Court Grants Stay Enabling Removal of Rebecca Kelly Slaughter as FTC Commissioner and Will Revisit Separation of Powers

On September 22, 2025, the U.S. Supreme Court granted on its emergency docket President Trump’s application for a stay of the lower federal court’s order for Rebecca Kelly Slaughter to be reinstated as FTC Commissioner after Trump fired her, and decided to revisit separation of powers issues, including whether to overrule its 1935 decision in Humphrey’s Executor v. United States.

Hunton Employment & Labor Perspectives

You May Also Be Interested In

Search

Recent Posts

Categories

Tags

Authors

Archives