McLeod v. Threlkeld

Summary

The Court, through Justice Reed, held that a contractor's cook serving an interstate railroad's maintenance-of-way employees was not engaged in commerce under the Fair Labor Standards Act and affirmed the judgment denying coverage. Coverage depends on the employee's activities, not the employer's business, and requires work actually in or sufficiently closely related to the movement of interstate commerce to be part of it. Supplying workers' personal needs did not satisfy that test. Justice Murphy dissented, joined by Justices Black, Douglas, and Rutledge. He would have reversed because the cook's work was sufficiently connected to interstate commerce, considered Philadelphia, Baltimore & Washington Railroad Company v. Smith controlling, and argued that the majority improperly imported a restrictive transportation test from Federal Employers' Liability Act decisions.