Christensen v. Harris County

PETITIONER: Christensen
RESPONDENT: Harris County
LOCATION: US District Court for the Eastern District of Pennsylvania

DOCKET NO.: 98-1167
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 529 US 576 (2000)
ARGUED: Feb 23, 2000
DECIDED: May 01, 2000

ADVOCATES:
Michael P. Fleming - Houston, Texas, argued the cause for the respondents
Michael T. Leibig - Argued the cause for the petitioner
Matthew D. Roberts - Argued the cause for the United States, as amicus curiae, by special leave of court

Facts of the case

The Fair Labor Standards Act of 1938 (FLSA) permits governmental entities to compensate their employees for overtime work by granting them compensatory time in lieu of cash payment. If the employees do not use their accumulated compensatory time, the employer must pay cash compensation under certain circumstances. Harris County, Texas, found that too many of its deputy sheriffs had too many hours of accrued compensatory time. Fearing a budget crisis, the county adopted a policy under which its employees could be ordered to schedule compensatory time at specified times in order to reduce the amount of accrued time that would otherwise require cash payment. Edward Christensen and 128 other deputy sheriffs in Harris County believed they had the right to use their compensatory time when they saw fit. The sheriffs sued, claiming that the FLSA does not permit an employer to compel an employee to use compensatory time in the absence of an agreement permitting the employer to do so. The District Court ruled in favor of the sheriffs, concluding that the policy violated the FLSA. In reversing, the Court of Appeals held that the FLSA did not address the issue in question and thus did not prohibit the county from implementing a compensatory time policy.

Question

Does the Fair Labor Standards Act of 1938 prohibit a public employer from compelling its employees to use their compensatory time without a preexisting agreement?

Media for Christensen v. Harris County

Audio Transcription for Oral Argument - February 23, 2000 in Christensen v. Harris County

Audio Transcription for Opinion Announcement - May 01, 2000 in Christensen v. Harris County

Sandra Day O'Connor:

The opinion of the Court in No. 98-1167, Christensen versus Harris County will be announced by Justice Thomas.

Clarence Thomas:

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Fifth Circuit.

Under the Fair Labor Standards Act commonly known as FLSA, states and ,municipalities may compensate their employees for overtime work by granting them compensatory time, which then entitles employees to time off with full pay.

Petitioners of Deputy Sheriffs of Harris County, they agreed to accept compensatory time instead of cash compensation.

As petitioners began accumulating hours of compensatory time, Harris County became concerned that the employees would not use their compensatory time by taking time off.

Under the FLSA, if employees do not use compensatory time, the County would have to pay the employees in cash for unused hours.

To avoid a budgetary crisis, the County ordered petitioners to use their accumulated compensatory time.

Petitioner sued, claiming that the FLSA prohibits the County from compelling employees to use this time.

The District Court agreed, but the Court of Appeals reversed, finding that nothing in the FLSA prohibits this compelled use.

In an opinion filed with the Clerk today, we affirm the judgment of the Court of Appeals.

Both petitioners and the United States as amicus curiae concede that nothing in the FLSA explicitly prohibits Harris County from requiring employees to use compensatory time.

Instead they argue that the FLSA implicitly prohibits such a practice in the absence of employee consent.

They contend that because the FLSA details some ways in which compensatory time can be used in the other ways including compelled use are implicitly foreclosed, we disagree.

The FLSA provision cited by petitioners and the United States simply ensure that employees receive some timely benefit for working overtime.

These provisions do not imply that an employer is prohibited from taking steps to make sure that employees actually use the compensatory time that they agreed to accept.

Citing our decision in Chevron v. Natural Resources Defense Council, petitioners and the United States also argue that we should defer to their reading because it is shared by the Department of Labor.

Prior to this lawsuit, the Department of Labor issued an opinion letter that interpreted the FLSA to prohibit compelled use.

We decline to give this opinion Chevron style deference.

Interpretations such as those in opinion letters like interpretations contained in policy statements, agency manuals, and enforcement guidelines lack the force of law and simply do not warrant Chevron deference.

Justice Scalia has filed an opinion concurring in part and concurring in the judgment; Justice Souter has filed a concurring opinion; Justice Stevens has filed a dissenting opinion in which Justice Ginsburg and Justice Breyer have joined; and Justice Breyer has filed a dissenting opinion in which Justice Ginsburg has joined.