Encino Motorcars v. Navarro

Under the Fair Labor Standards Act, 29 U.S.C. §231(b)(10)(A), automobile dealership service advisors are not entitled to overtime compensation because they are "salesm[e]n ... primarily engaged in ... servicing automobiles."

Respondents, current and former automobile service advisors employed by Petitioner, sued for backpay of overtime wages alleging that Petitioner violated the Fair Labor Standards Act (FLSA). The FLSA’s overtime-pay requirement provides an exemption for “any salesman . . . primarily engaged in selling or servicing automobiles . . .” 29 U.S.C. §231(b)(10)(A). the Ninth Circuit held that the exemption did not apply to Respondents. The Supreme Court, having no statutory definition of “salesman” to apply, gave the term “service advisor” its ordinary meaning under which the court found that a service advisor is clearly a “salesman.” Further, the Court found that service advisors are “primarily engaged in servicing automobiles” because they play an integral role in the servicing of automobiles and that language of the statute did not constrain this exemption to mechanics or others who physically repair cars. The Court rejected the Ninth Circuit’s use of the distributive canon as an unnatural fit because it requires that the reader switch between distributive and disjunctive interpretation within the provision. Finally, the court found that the FLSA, lacking any textual indication that it should be construed narrowly, must be given a “fair reading.” Automobile dealership service advisors are exempt from overtime pay under the FLSA. VACATED and REMANDED.