Supreme Court of the United States

Encino Motorcars, LLC, Petitioner v. Hector Navarro

April 2, 2018584 U.S. 79

Summary

The Supreme Court held that automobile-dealership service advisors are exempt from the FLSA's overtime-pay requirement under 29 U.S.C. § 213(b)(10)(A) because they are "salesmen primarily engaged in servicing automobiles." Giving the undefined statutory terms their ordinary meanings, the Court reasoned that service advisors sell services for vehicles and are integral to the servicing process; it rejected the Ninth Circuit's distributive-canon reading, declined to construe FLSA exemptions narrowly, and found the Occupational Outlook Handbook and legislative-history silence unpersuasive. The Court reversed and remanded. Justice Ginsburg, joined by Justices Breyer, Sotomayor, and Kagan, dissented, contending that Congress enumerated only three exempt occupations, that service advisors neither sell nor repair automobiles, and that the majority wrongly discarded the longstanding narrow-construction principle.

Holding

  • Whether service advisors are "salesmen" under § 213(b)(10)(A). Yes. A service advisor is obviously a "salesman" because the ordinary meaning of salesman is someone who sells goods or services, and service advisors sell customers services for their vehicles.
  • Whether service advisors are "primarily engaged in servicing automobiles". Yes. "Servicing" can mean either maintaining or repairing a motor vehicle or providing a service, and service advisors satisfy both definitions; the phrase includes individuals who do not physically repair cars but are integral to the servicing process.
  • Whether the distributive canon excludes service advisors by matching "salesman" to "selling" and "partsman"/"mechanic" to "servicing". No. Context favors the ordinary disjunctive meaning of "or," so the exemption covers a salesman primarily engaged in either selling or servicing automobiles.
  • Whether FLSA exemptions must be construed narrowly. No. The Court rejects the narrow-construction principle as a useful guidepost for interpreting the FLSA and gives the exemption a fair reading.
  • Whether the Occupational Outlook Handbook and legislative-history silence defeat coverage. No. Neither the Department's 1966-1967 Occupational Outlook Handbook nor the absence of any mention of service advisors in the legislative history persuades the Court; silence in the legislative history cannot defeat the better reading of the text.

Docket 16–1362.

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