Christensen v. Harris County

Christensen v. Harris County

Argued February 23, 2000
Decided May 1, 2000
Full case name Edward Christensen, et al. v. Harris County, et al.
Citations

529 U.S. 576 (more)

120 S. Ct. 1655; 146 L. Ed. 2d 621
Prior history 158 F.3d 241 (affirmed)
Holding
An opinion letter from the Department of Labor stating that an employer had to first get the employee to agree before requiring the employee to schedule time off did not receive Chevron deference and instead should receive the less deferential standard of Skidmore v. Swift.
Court membership
Case opinions
Majority Thomas, joined by Rehnquist, O'Connor, Kennedy, Souter, and Scalia (except for Part III)
Concurrence Souter
Concurrence Scalia (concurring in the judgment and all but Part III)
Dissent Stevens, joined by Ginsburg and Breyer
Dissent Breyer, joined by Ginsburg
Laws applied
Fair Labor Standards Act, 29 U.S.C.S. § 201 et seq.

Christensen v. Harris County, 529 U.S. 576 (2000) is a Supreme Court of the United States case holding that a county's policy of requiring that employees schedule time off so that they do not accrue time off was not prohibited by the Fair Labor Standards Act.

Facts

The sheriff's department in Harris County, Texas, in an attempt to reduce overtime expenditures, forced deputies to use accumulated compensatory time before they reached the limit which would require overtime payments. The petitioners argued that the Fair Labor Standards Act prohibited the forced use of "comp time." Respondents argued that the FLSA allows cashing out comp time and does not guarantee a minimum 40 hour work week.

The United States Department of Labor had issued an opinion letter stating that the forced use of comp time violated the act.

Judgment

The Court held that an opinion letter from the Department of Labor stating that an employer had to first get the employee to agree before requiring the employee to schedule time off did not receive Chevron deference and instead should receive the less deferential standard of Skidmore v. Swift & Co. The majority attempted to draw a bright line between formal agency documents (e.g., legislative rules) and less formal ones (e.g., opinion letters). Therefore, the opinion letter of the Department of Labor was not binding on the court. The court went on to state that there is nothing in the FLSA that prohibited the forced use of comp time. Justice Thomas delivered the 6-3 decision of the court in favor of Respondent Harris County. The case was argued on behalf of the United States by Matthew D. Roberts, for Petitioner by Michael T. Leibig and for Harris County, Texas by Michael P. Fleming.[1][2]

Notes

  1. "Christensen v. Harris County - 529 U.S. 576 (2000)". Oyez. Retrieved 22 October 2013.
  2. "Christensen v. Harris County - 529 U.S. 576 (2000)". Justia: The US Supreme Court Center. Retrieved 22 October 2013.

See also

External links