Encino Motorcars, LLC v. Navarro

Facts of the Case

Respondents, current and former service advisors for petitioner Encino Motorcars, LLC, sued petitioner for backpay, alleging that petitioner violated theby failing to pay them overtime. Petitioner moved to dismiss, arguing that service advisors are exempt from theovertime-pay requirement under, which applies to “any salesman, partsman, or mechanic primarily engaged in selling or servicing automobiles, trucks, or farm implements.” The District Court agreed and dismissed the suit. The Court of Appeals for the Ninth Circuit reversed. It found the statute ambiguous and the legislative history inconclusive, and it deferred to a 2011 Department of Labor rule that interpreted “salesman” to exclude service advisors. This Court vacated the Ninth Circuit’s judgment, holding that courts could not defer to the procedurally defective 2011 rule,(

Question

“1) Does a city employee have a reasonable expectation of privacy in text messages transmitted on his city-issued pager when the police department has no official privacy policy for the pagers?2) Did the Ninth Circuit contravene Supreme Court precedent by analyzing whether the police department could have used “less intrusive methods” of reviewing text messages?”

CONCLUSION

“In a 5-4 decision, the Court reversed and remanded the case back to the Ninth Circuit, holding that because service advisors at car dealerships are “salesm[e]n . . . primarily engaged in . . . servicing automobiles,” 29 U.S.C. § 213(b)(10)(A), they are exempt from the FLSA’s overtime-pay requirements.Construing the relevant portions of the statute, the Court explained that a service advisor is clearly a “salesman” who sells services to customers for their vehicles. The Court also concluded that service advisors are “primarily engaged in . . . servicing automobiles” since they are integral in the process of providing maintenance and repair services to customers, even if they do not spend most of their time physically repairing vehicles. The Court rejected the Ninth Circuit’s use of the distributive canon, as well as its conclusion that FLSA exemptions should be construed narrowly in holding that service advisors were not exempt.  It also rejected the appellate court’s reliance on a 1966-67 DOL Occupational Outlook Handbook and the FLSA legislative history, both of which the Court found unpersuasive.Justice Ginsburg filed a dissenting opinion, in which Justices Breyer, Sotomayor, and Kagan joined.”

Case Information

Citation: 584 US (2018)
Granted: Sep 28, 2017
Argued: Jan 17, 2018
Decided: Apr 2, 2018
Case Brief: 2018