Essay on Navigating Overtime Compensation: A Legal Analysis Under the Fair Labor Standards Act

Published: 2023-11-11
Essay on Navigating Overtime Compensation: A Legal Analysis Under the Fair Labor Standards Act
Essay type:  Analytical essays
Categories:  Company Law Court system Public administration
Pages: 8
Wordcount: 1950 words
17 min read


In 1994 at Fort Worth, Texas, Skidmore, and his six colleagues (plaintiff) sued their employer Swift and Company (defendant) for an estimated $ 77,000 due in overtime compensation. The plaintiffs filed a lawsuit against their employer under the Fair Labor Standards Act (the Act), 29 U.S.C.A. § 201 on the foundation of the Administrator of the U.S. Department of Labor's Wage and Hour Division's interpretative bulletin about the interpretation of the Act in a different situation. The guidance forwarded in the newsletter emphasized the flexible application of the Act; in this context, it required consideration when employees spend time on non-work related issues while on duty and hours spent on standby without productive work. Even so, the trial court held that the time employees spent during night shifts in the company's fire hall did not count as compensatory overtime work. While the Court of Appeal ruled in favor of the trial court decision, the Supreme Court reversed the judgment and granted certiorari to the plaintiffs.

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Basis of the Case

The plaintiffs worked in a daytime shift for five days a week, and also as required by their work schedule, they worked three to four nights per week, nightshift staff stayed in the company's fire hall. The plaintiffs' work schedule ensured that the work was there were no staffing gaps in their work, while others worked during the day; others served as a relief. The atypical working day started from 7:00 a.m. to 3:30 p.m. with an hour lunch break in between. Each employee had to work five days a week and received weekly wages. The daytime duties included doing general work in the fire hall, and equipment maintenance of equipment; some employees were engaged in elevator operation while others served as relief men. The night shift duty was mainly to respond to fire alarms; there was an oral agreement that they were not supposed to carry out any other task.

According to the complainants, the company only paid them for the night they responded to fire alarms but were not paid for additional nights. During that time, there were no cases of fires reported, and most of the nights were uneventful with call time for the employees not exceeding one hour. The trial court did not recognize that the plaintiffs spend their nights at work, and that should be accounted for as work. The conclusion by the trial court underestimated the fact that if it were not for duty calls, an employee would be away from the company's premises doing other personal things.

The Trial Court Findings

The company provided several facilities such as a warm fire hall with comfortable air-conditioned rooms to motivate its staff. Also, the building had gaming equipment, stereos, and nap rooms. The findings revealed that the company provided the incentives mentioned above to ensure that its staff enjoyed their time at work and, most importantly, to be near the fire hall at all times to respond to fire alarms efficiently. Moreover, as stipulated in the company's compensation plan, for every fire alarm acted on, the company paid an initial payment of fifty cents and later sixty-four cents; this payment was in addition to their agreed fixed-wage amount. Perhaps the ruling of the trial court was based on this of staff motivation, and it forgets to consider that time spent waiting for a fire alarm can translate to work as every minute counts.

The testament presented to the trial court did not reveal if the events were under the parties' arrangement or the circumstances of this case. This case is different from the Armour case being on duty or in any other part constitutes working time. However, as a "conclusion of law," the time plaintiffs spent in the fire hall waiting to respond to fire alarms cannot be included in overtime compensation as stipulated in the Fair Labor Standards Act. Moreover, the Circuit Court of Appeal upheld the trial's Court, stating that time spent on personal activities while on duty is not considered work.

Interpretation of the Administrator's Policy

The courts had a greater responsibility to determine if the cases were within or out of the Act since Congress made minimal use of the administrative agency services (Kirschbaum v. Walling, 316 U.S. 517, 523, 62 S.Ct. 1116, 112); creating the position of an administrator bestowed with various tasks to notify oneself on the settings of industries and employees subjected to the Act of and also assume the duties of imposing ban against the violations of the Act. The responsibilities assigned to the Administrator have been vital in providing a transparent background in ascertaining the working time of employees involved in intervals of inactivity and being aware of the customs that would be important in bringing about a solution [323 U.S. 134, 138]. This reason compelled the administrator to make various conclusions about whether to conduct without following the rule of law for him to seek the mandate to stop it by law to avoid any interference. The Administrator also proposed various views on how the Act was applicable under different prospects in multiple rulings; this was important as it provided a reasonable guideline to employers and employees on how the Administrator's office is essential in the representation of the public interest and how its application through effective enforcement(Krishnakumar, 2014).

From the administrator's point of view, the best solution to inactive duties requires a flexible solution as compared to that of all-in or all-out rules that were adopted by the involved parties in the case he also provided various suggestions on the standards and gave various examples as a guideline in a specific situation. In some occupations such as an operator of a small telephone exchange, subjecting employees to calls during durations of inactivity cannot be suitably counted as time of work (Krishnakumar, 2014). The telephone operator with the switchboard at her house typically gets several hours of uninterrupted sleep every night. It generally confides on the extent to which an employee is ready to be involved in other activities during his idol time—requiring him to be on call and the many hours that employees may be required to be on call. However, he may not be required to be on ongoing work both the time an employee spent in active labour and the time given by the employee to the employer constitutes hours work [323 U.S. 134, 139. The amicus' expression generally suggested the exclusion of the time to sleep and eat from the routine of all week-long work and including all others at the time of the call. Since the employees had to stay within the place of work the entire time, the outcome showed that during their regular sleeping and eating time disruptions were infrequent, this was proof enough to show that there was an occupation of employees' time were on duty or not. This time could be used appropriately and comfortably in the deserved circumstances; the other time, it was different because no evidence was found showing the time used for personal activities depends on how one chooses to as they were free to do (Messenger, 2018).

There is no lawful arrangement as to how the courts should pay the Administrator for his findings. Even with notice, there was no effort to determine their impact. The Administrator rulings do not depend on proceedings hearing to find evidence and find a satisfactory outcome from the facts. Administrators mainly use correlation in various cases that they directly deal with; they do not interpret the Act of law or use certain specific regulations in making their conclusions on factual situations. It is the Administrator's official duty to establish policies, which depend on highly experienced and extensively investigated information that can reach the desk of a judge in a similar case. Administrators determine the guidelines used in various policies that guide the application for enforcement. Effective use of the Act that goes hand in hand with valid judicial legislation and it is required to meet public administration specifications, and it should consider those that regulate a private individual's rights shall be at variance where there is a good reason for advocating it (Morrero, 2014). Because trials in any form do not determine administration policies and findings, they should be respected. The Court gave a more profound concern to the treasury decisions and various critical regulations to the treasury and other organizations that were not of adversary source. The Administrator's rulings, analysis, and views under the Act, were not controlled by the courts despite their authority and did not entail detailed information and informed judgment that may provide a useful guideline that can be used by the Court in making proper decisions. In such a case, the decisions will mainly depend upon the consciousness portrayed in its consideration, the legitimacy behind the reasoning, and its consistency, among other factors that can be convincing.

The courts had to weigh various facts that were of significant concern in the case, in the light of the Administrator's rulings, and came to a consistent conclusion. The evidence such as separate compensation for answering the alarm was a different case and each case had to stand on its facts. The District Court attributed the Administrator's findings as an interpretation. The Court confined its hearing to the assumption that time of waiting may not be working time, with a clear understanding of the law, did not term this notion to be misguided. The Supreme Court reversed the case and remanded it for further proceedings.

The issue of contention was waiting time, excluding in between lunch breaks and resting time, constituted working time. I strongly agree with this fact as explained and the rule from the district court being as stated, therein; for both the Fair Labor Standards Act and the district court, there was no set of principles of law that barred duty call waiting time from being considered as working time. It is too hard for the legal formula to resolve individual cases that have varying findings. In such a situation, time can either be within or without the Act, and should be determined by well-researched findings by the trial court; this involves considering and developing the agreed terms among the parties, evaluating of construction of their accepted conduct, the type of the service provided, how it linked directly to the waiting time, and all other involved characteristics (Messenger, 2018).

The Fact Being

Some of the employees occupied themselves in fire-hall general duties and the maintenance of the company's firefighting equipment during that time; others served as duty relievers. The employees also had made a mutual agreement with the employer to be within the company's premises or in a nearby place when on night shift scheduled. During the night shift hours, the employees could not perform any task apart from answering fire alarms. When the plaintiffs filed the case to recover overtime, the district court followed the rule of law, observing that the waiting time to respond to fire alarms is not accounted for as working hours. The Court of Appeal maintained the ruling of the trial court.


The Court ruled that the time spent working could not also be time spent waiting, specifically in these cases where the nature of employment involves a lot of waiting time. Congress granted the courts the authority to determine the claim's facts and whether the actions in dispute include working, although it can be severe and rare cases to be done. On that note, the Court ruled out the decisions of lower courts, terming them as erroneous knowledge of the law, classifying waiting time to be a different time from working time.

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Essay on Navigating Overtime Compensation: A Legal Analysis Under the Fair Labor Standards Act. (2023, Nov 11). Retrieved from

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