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Encino Motorcars, LLC v. Navarro et al (US 2016)

Articles Discussing Case:

U.S. Supreme Court Rules Automobile Dealership Service Advisors Not Entitled to Overtime-Pay under FLSA

Goldberg Segalla LLP • April 09, 2018
On April 2, 2018, in Encino Motorcars, LLC v. Hector Navarro, et al., the U.S. Supreme Court held that automobile dealership “service advisors” are exempt from the Fair Labor Standards Act (FLSA) overtime-pay requirement under 29 U.S.C. § 207(a), which requires that an employer pay overtime to covered employees who work more than 40 hours in a week. The exemption at issue applies to “any salesman, partsman, or mechanic primarily engaged in selling or servicing automobiles, trucks, or farm implements...” § 213(b)(10)(A). Petitioner Encino Motorcars, LLC was a Mercedes-Benz dealership in California. Respondents were current and former service advisors for the petitioner.

Supreme Court Exempts Auto Service Advisors from Overtime, Rejects ‘Narrow Construction’ Principle in Applying FLSA Exemptions

Jackson Lewis P.C. • April 04, 2018
After years of litigation, including two trips to the U.S. Supreme Court, on whether service advisors who work in an automobile dealership are exempt from overtime under the Fair Labor Standards Act (FLSA), the Court finally has held, in a 5-4 decision, that service advisors are exempt from overtime under the “automobile dealer” exemption applicable to salesmen, partsmen, and mechanics. Encino Motorcars, LLC v. Navarro, 2018 U.S. LEXIS 2065 (Apr. 2, 2018). But the case has implications far beyond the industry-specific exemption.

Supreme Court Rules that Service Advisors at Automotive Dealerships are Exempt from Overtime and Rejects Principle that Exemptions to FLSA Should be Construed Narrowly

FordHarrison LLP • April 03, 2018
Executive Summary: On April 2, 2018, the U.S. Supreme Court ruled 5-4 in Encino Motorcars, LLC v. Navarro that service advisors at automotive dealerships are exempt from overtime. The exemption at issue involves “any salesman, partsman or mechanic primarily engaged in selling or servicing automobiles.” 29 U.S.C. 213 (b)(10). The Supreme Court reversed the Ninth U.S. Circuit Court of Appeals which had ruled that based on a plain reading of statutory text, principles of statutory interpretation (narrow construction of FLSA exemptions), and legislative history, the exemption does not encompass service advisors.

eLABORate: U.S. Supreme Court Reverses Ruling: Auto Service Advisors Will Not Receive Overtime Pay

Phelps Dunbar LLP • April 03, 2018
On April 2, 2018, in Encino Motorcars, LLC v. Navarro et al.,the United States Supreme Court held that service advisors at car dealerships are exempt from the overtime-pay requirements of the Fair Labor Standards Act (FLSA). That is, dealerships are not required to pay service advisors time and half for working more than 40 hours in a week. The Court based its decision on the application of an exemption to the FLSA. The Court also reversed a Ninth Circuit decision holding that the exemption did not apply to service advisors.

SCOTUS Rules That Car Dealership Service Advisors Are Exempt, Puts the Brakes On Overtime Claims

Ogletree Deakins • April 03, 2018
In its April 2, 2018, decision in Encino Motorcars, LLC v. Navarro, the Supreme Court of the United States issued its second opinion in this case and definitively ruled that automobile service advisors are exempt from overtime under section 213(b)(10)(A) of the Fair Labor Standards Act (FLSA). The sole question before the Court was whether a service advisor is a salesman who is “primarily engaged in . . . servicing automobiles.” In a 5-4 decision, Justice Thomas wrote for the majority stating that the best reading of the statutory text leads to the conclusion that service advisors are exempt from overtime because they are salesmen in that they do make sales of services for vehicles and they are primarily engaged in servicing automobiles.

Supreme Court Rules Auto Service Advisers Are Exempt From Overtime

Franczek Radelet P.C • April 03, 2018
Earlier today (April 2, 2018), the U.S. Supreme Court ruled that auto service advisers (also commonly referred to as “service writers”) are exempt from overtime under the Fair Labor Standards Act (“FLSA”). Today’s ruling in Encino Motorcars LLC v. Navarro et. al. has affirmatively answered the long-standing question as to whether auto service advisers are covered by the FLSA’s “salesman” overtime exemption, which includes “any salesman, partsman or mechanic primarily engaged in selling or servicing automobiles.” The Court’s decision overturned the Ninth Circuit Court of Appeals ruling that service advisors do not fall under the exemption, and followed rulings in both the Fourth and Fifth Circuit Court of Appeals holding that they were exempt from overtime.

Supreme Court Rejects Deference to DOL Regulation on FLSA Exemption Due to Failure to Provide Reasoned Explanation for Change

Jackson Lewis P.C. • June 23, 2016
The Supreme Court granted certiorari in Encino Motorcars, LLC v. Navarro, No. 15-415 (June 20, 2016), to resolve a circuit court split regarding whether “service advisors” are exempt from receiving overtime pay under the Fair Labor Standards Act (FLSA). Although the parties thoroughly briefed the issue, the Court did not resolve the question. Instead, as Justice Clarence Thomas noted in his dissent, the Court decided to “punt” (likely due to an inability to garner a majority opinion because of the vacancy at the Court caused by Justice Antonin Scalia’s death that has left it with just eight members since February). Automobile dealers are likely to face uncertainty a while longer.

The Supreme Court Shoots Down DOL Regulations, But Declines To Rule Whether Service Advisors are Exempt From Overtime Pay Requirements

Franczek Radelet P.C • June 22, 2016
Yesterday, the United States Supreme Court issued its long-awaited decision in the Encino Motorcars, LLC v. Navarro case, that many hoped would resolve the issue as to whether Service Advisors at auto dealerships are exempt from the overtime provisions of the Fair Labor Standards Act (FLSA).

Supreme Court Calls “Do Over” On FLSA Service Advisor Exemption Rule

Fisher Phillips • June 21, 2016
In a 6 to 2 decision, the U.S. Supreme Court today continued the flip-flop-flip on determining whether an automobile dealership’s service advisors are exempt from the FLSA’s overtime requirements. The Court vacated and remanded the case back to the 9th Circuit Court of Appeals for further proceedings, essentially calling a “do over.” For dealerships in the 9th Circuit – those in California, Washington, Nevada, Arizona, Oregon, Alaska, Hawaii, Idaho, and Montana – this case provides a hopeful reprieve (Encino Motorcars, LLC v. Navarro et al).