Law School Case Brief
Battaglia v. Gen. Motors Corp. - 169 F.2d 254 (2d Cir. 1948)
While Congress has the power to give, withhold, and restrict the jurisdiction of courts other than the Supreme Court, it must not so exercise that power as to deprive any person of life, liberty, or property without due process of law or to take private property without just compensation.
Battaglia and others were employees of General Motors Corporation (GMC). They brought suit against GMC to recover overtime pay in accordance with the provisions of the Fair Labor Standards Act of 1938 and liquidated damages, plus reasonable attorney's fees, for time upon GMC's premises preliminary to, and after engagement in, the principal activities of the employees. While these suits were pending, Congress enacted the Portal-to-Portal Act of 1947, and the trial court dismissed the complaint for failure to allege that the compensation sought was for activities that were compensable by an express provision of a written or nonwritten contract or by a custom or practice in effect at the time of the activities and at the place of employment. Battaglia and the employees sought review, claiming that the Portal-to-Portal Act was unconstitutional.
Was the Portal-to-Portal Act of 1947 unconstitutional?
The Court held that Portal-to-Portal Act of 1947 was valid as it was not arbitrarily or discriminatorily enacted, did not take vested rights, did not violate U.S. Const. art. III, and did not encroach upon the separate power of the judiciary. Thus, it survived constitutional challenge. As a result, the dismissal of plaintiff employees' complaints to recover overtime pay was affirmed.
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