Supreme Court of the United States
Addison v. Holly Hill Fruit Products, Inc.
June 5, 1944322 U.S. 607
Summary
The Court held that the Fair Labor Standards Act’s exemption for workers "within the area of production (as defined by the Administrator)" limits the Administrator to geographic definitions only and invalidates any employee‑number limitation; consequently the regulation must be struck in its entirety and the case remanded to the district court to await a valid Administrator determination. Justice Rutledge dissented, arguing the definition was valid and the employees were exempt, while Justice Roberts concurred in part, agreeing the limitation was invalid but would have affirmed the appellate court rather than remand.
Holding
- Whether the Administrator may include a limitation on the number of employees in the definition of "area of production" under §13(a)(10) of the Fair Labor Standards Act.. The Administrator lacks authority to impose an employee‑number limitation; such limitation is ultra vires and must be invalidated.
- Whether the geographic conditions of the regulation (population under 2,500 and all commodities within ten miles) satisfy the statutory requirements.. The population condition is satisfied, but the ten‑mile condition is not met because a small percentage of fruit was sourced from beyond ten miles; therefore the regulation’s geographic portion is invalid as applied to Holly Hill.
- Whether, if the employee‑number limitation is invalid, the remainder of the Administrator's definition can be severed or must be struck in its entirety.. Because the employee‑number limitation is an integral part of the definition, the entire definition must be struck; the Court cannot assume the Administrator would have adopted the same geographic definition without the limitation.
Docket 217
Cited authorities
- 52 Stat. 1060
- 49 Stat. 449
- 52 Stat. 1067
- 53 Stat. 1266