Law School Case Brief
Christensen v. Harris County - 529 U.S. 576, 120 S. Ct. 1655 (2000)
A court must give effect to an agency's regulation containing a reasonable interpretation of an ambiguous statute. Interpretations such as those in opinion letters, like interpretations contained in policy statements, agency manuals, and enforcement guidelines, all of which lack the force of law, do not warrant such deference. Interpretations contained in formats such as opinion letters are entitled to respect, but only to the extent that those interpretations have the power to persuade.
The Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. § 201(o), permits States and their political subdivisions 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. §§ 207(o)(3)-(4). Fearing the consequences of having to pay for accrued compensatory time, Harris County (Texas) adopted a policy requiring its employees to schedule time off in order to reduce the amount of accrued time. Petitioners, 127 county deputy sheriffs, brought this suit against the sheriff, Tommy B. Thomas, and Harris County, 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 granted petitioners summary judgment and entered a declaratory judgment that the policy violated the FLSA. The United States Court of Appeals for the Fifth Circuit reversed, holding that the FLSA did not speak to the issue and thus did not prohibit the county from implementing its policy. The deputy sheriffs filed a petition for certiorari review.
Did the policy of requiring employees to schedule time off from work in order to prevent them from accumulating enough compensatory time to require cash compensation violate the Fair Labor Standards Act, 29 U.S.C.S. §§ 201 et seq.?
The United States Supreme Court affirmed the judgment that held that under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C.S. §§ 201 et seq., states and their political subdivisions may require employees to schedule time off in order to reduce the amount of accrued compensatory time. Under the FLSA, employers were required to compensate their employees for overtime by granting them compensatory time. Once employees accrued a certain amount of compensatory time, employers were required to pay cash compensation for the accrued time. Respondent implemented policy requiring employees to schedule time off in order to reduce the amount of accrued compensatory time. The Court held that there was nothing in the statute that prohibited this policy. The Court rejected petitioners' argument that a provision in the statute that granted control to employees to use compensatory time implied that all other methods of spending compensatory time were precluded. The Court found that provision, viewed in the context of the overall statutory scheme, was better read as setting up a safeguard to ensure that an employee will receive timely compensation for working overtime.
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