Minute Summary
The Fair Labor Standards Act (FLSA) requires most employees to be paid overtime, but certain jobs are exempt from this requirement. A group of sales representatives sued their employer, EMD, for unpaid overtime. EMD argued that the sales reps were “outside salesmen” and therefore not covered by the overtime rule. However, the lower courts ruled against EMD, saying the company had to prove its case with clear and convincing evidence, a stricter standard. The Supreme Court disagreed, ruling that employers only need to meet the preponderance of the evidence standard, which is easier to prove. The case was sent back to the lower courts to be reconsidered under this standard.
Important Definitions
Fair Labor Standards Act (FLSA): A federal law that guarantees minimum wage and overtime pay to most workers.
Overtime Pay: Extra pay required when an employee works more than 40 hours a week.
Outside Salesman: A worker whose job mainly involves making sales away from the employer’s office or store.
Preponderance of the Evidence: The standard of proof in most civil cases, meaning something is more likely true than not.
Clear and Convincing Evidence: A higher standard of proof requiring strong certainty in the evidence.
Extended Summary
In E.M.D. Sales, Inc. v. Carrera, the Supreme Court addressed a dispute over how much proof an employer needs to show that its workers are not entitled to overtime pay under the Fair Labor Standards Act (FLSA). The law requires most employees to be paid overtime, but some jobs, such as outside salesmen, are exempt.
EMD, a food distribution company, employed sales representatives who worked in grocery stores managing inventory and taking orders. Several employees sued EMD, arguing they were not outside salesmen and should have been paid overtime. After a trial, the lower court ruled in favor of the employees, saying EMD had not proven they were outside salesmen using the clear and convincing evidence standard. The appeals court agreed, following a rule in its circuit that required this higher burden of proof.
However, the Supreme Court ruled that this was incorrect. The Court explained that in most civil cases, the standard of proof is preponderance of the evidence, which means that something is more likely true than not. The Court found no reason to apply a stricter standard in FLSA cases. Because the lower courts used the wrong standard, the Supreme Court sent the case back to be reconsidered under the correct, easier-to-meet preponderance of the evidence standard.
It is so ordered.
Think of It Like This
Imagine a school has a rule that students must stay after class if they don’t finish their homework, but there’s an exception for students who had to miss school for an important reason. A student named EMD says they shouldn’t have to stay after because they were at a doctor’s appointment. The teacher, following a strict rule, says EMD must prove beyond a doubt that they were really at the doctor’s office. But the principal steps in and says that’s too strict—the student should only have to reasonably show that they had a valid excuse. The principal then sends the issue back to the teacher to reconsider under the right rule.
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