April 2, 2018
Encino Motorcars, LLC v. Navarro, No. 16-1362
Decided April 2, 2018
Today, the Supreme Court held 5-4 that car dealership service advisors are exempt from the Fair Labor Standards Act’s requirement to pay overtime.
The Fair Labor Standards Act (FLSA) contains an exemption from its overtime-pay requirements for “any salesman, partsman, or mechanic” who is “primarily engaged in selling or servicing automobiles.” 29 U.S.C. § 213(b)(10)(A). Service advisors are car dealership employees who meet with customers, identify their service needs, and sell them services for their vehicles. They sued, claiming that they are entitled to overtime pay under the FLSA.
Whether service advisors at car dealerships are exempt from the Fair Labor Standards Act’s overtime-pay requirements.
Yes, service advisors are exempt because they qualify as “salesmen . . . primarily engaged in . . . servicing automobiles” under the FLSA.
“If the text is clear, it needs no repetition in the legislative history; and if the text is ambiguous, silence in the legislative history cannot lend any clarity.”
writing for the majority
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