Helix Energy Solutions Group, Inc. v. Hewitt

Last updated

Helix Energy Solutions Group, Inc. v. Hewitt
Seal of the United States Supreme Court.svg
Argued October 12, 2022
Decided February 22, 2023
Full case nameHelix Energy Solutions Group, Inc., et al. v. Michael J. Hewitt
Docket no. 21-984
Citations598 U.S. 39 ( more )
Argument Oral argument
Opinion announcement Opinion announcement
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Neil Gorsuch  · Brett Kavanaugh
Amy Coney Barrett  · Ketanji Brown Jackson
Case opinions
MajorityKagan, joined by Roberts, Thomas, Sotomayor, Barrett, Jackson
DissentGorsuch
DissentKavanaugh, joined by Alito
Laws applied
Fair Labor Standards Act of 1938

Helix Energy Solutions Group, Inc. v. Hewitt, 598 U.S. 39 (2023), was a United States Supreme Court case related to the Fair Labor Standards Act of 1938.

Contents

Background

Michael Hewitt was a toolpusher (a supervisor) on oil rigs for Helix Energy Solutions Group from 2014 to 2017. He was paid over $200,000 each year he worked for the company, at a flat daily rate. Hewitt was fired from the company in 2017, and the reasons are in dispute. He then filed a collective action under the Fair Labor Standards Act (FLSA) against Helix, asserting he was entitled to overtime pay. Various FLSA regulations exempt employees from overtime if they (1) perform managerial duties, (2) earn $100,000 or more each year, and (3) receive a weekly salary of $455 or higher on a salary basis. Hewitt fulfilled the first two conditions, but not the third, as he was paid daily. The United States District Court for the Southern District of Texas rejected Hewitt's claim, but the United States Court of Appeals for the Fifth Circuit reversed in a 2–1 opinion. The court later granted rehearing en banc and again reversed, this time in a 12–6 vote in an opinion by Judge James C. Ho.

Helix filed a petition for a writ of certiorari. [1]

Supreme Court

Certiorari was granted in the case on May 2, 2022. Oral arguments were held on October 12, 2022. On February 22, 2023, the Supreme Court affirmed the Fifth Circuit in a 6–3 decision.

Related Research Articles

Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946), is a decision by the US Supreme Court that held that preliminary work activities, if controlled by the employer and performed entirely for the employer's benefit, are properly included as working time under Fair Labor Standards Act. The decision is known as the "portal to portal case."

Auer v. Robbins, 519 U.S. 452 (1997), is a United States Supreme Court case that concerns the standard that the Court should apply when it reviews an executive department's interpretation of regulations established under federal legislation. The specific issue was whether sergeants and lieutenants in the St. Louis Police Department should be paid for working overtime. The Fair Labor Standards Act of 1938 established the overtime pay requirement, and the US Department of Labor issued regulations to determine if an employee was covered by the overtime requirement.

Jacques Loeb Wiener Jr. is a Senior United States Federal Judge of the United States Court of Appeals, Fifth Circuit in New Orleans, Louisiana.

<span class="mw-page-title-main">Fair Labor Standards Act of 1938</span> United States wage law

The Fair Labor Standards Act of 1938 29 U.S.C. § 203 (FLSA) is a United States labor law that creates the right to a minimum wage, and "time-and-a-half" overtime pay when people work over forty hours a week. It also prohibits employment of minors in "oppressive child labor". It applies to employees engaged in interstate commerce or employed by an enterprise engaged in commerce or in the production of goods for commerce, unless the employer can claim an exemption from coverage. The Act was enacted by the 75th Congress and signed into law by President Franklin D. Roosevelt in 1938.

Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985), is a landmark United States Supreme Court decision in which the Court held that the Congress has the power under the Commerce Clause of the Constitution to extend the Fair Labor Standards Act, which requires that employers provide minimum wage and overtime pay to their employees, to state and local governments. In this case, the Court overruled its previous decision in National League of Cities v. Usery, in which the Court had held that regulation of the activities of state and local governments "in areas of traditional governmental functions" would violate the Tenth Amendment to the United States Constitution.

Skidmore v. Swift & Co., 323 U.S. 134 (1944), is a United States Supreme Court decision holding that an administrative agency's interpretative rules deserve deference according to their persuasiveness. The court adopted a case-by-case test, the Skidmore deference, which considers the rulings, interpretations, and opinions of the administrator. The Supreme Court reversed and remanded the case for further proceedings.

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 employees to schedule time off to avoid accruing time off was not prohibited by the Fair Labor Standards Act.

<span class="mw-page-title-main">2001 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down nine per curiam opinions during its 2001 term, which began October 1, 2001, and concluded October 6, 2002.

Christopher v. SmithKline Beecham Corp., 567 U.S. 142 (2012), is a US labor law case of the United States Supreme Court. It held that pharmaceutical sales representatives were not eligible for overtime pay. The court ruled in a majority opinion written by Justice Samuel Alito that sales representatives were classified as "outside salesmen" who are exempt from the Department of Labor's regulations regarding overtime pay.

Integrity Staffing Solutions, Inc. v. Busk, 574 U.S. 27 (2014), was a unanimous decision by the United States Supreme Court, ruling that time spent by workers waiting to undergo anti-employee theft security screenings is not "integral and indispensable" to their work, and thus not compensable under the Fair Labor Standards Act (FLSA). The Court delivered their ruling on December 9, 2014.

Tyson Foods, Inc. v. Bouaphakeo, 577 U.S. 442 (2016), was a United States Supreme Court case in which the Court affirmed the decision of the United States Court of Appeals for the Eighth Circuit, which held that representative evidence could be used to support the claims of the class. The case arose as a class action lawsuit against Tyson Foods. The Supreme Court affirmed the Eighth Circuit's judgment that the class satisfied the predominance requirement of the Federal Rules of Civil Procedure's Rule 23 and that the use of representative evidence was allowable in this case. It has been cited by lower courts and has spawned significant academic discussion.

Encino Motorcars v. Navarro, 579 U.S. ___ (2016), 584 U.S. ___ (2018), was a Supreme Court of the United States case addressing overtime pay. Specifically at issue is whether automotive service advisors are eligible for overtime pay under the Fair Labor Standards Act.

Epic Systems Corp. v. Lewis, 584 U.S. ___ (2018), was a case decided by the Supreme Court of the United States on how two federal laws, the National Labor Relations Act (NLRA) and the Federal Arbitration Act (FAA), relate to whether employment contracts can legally bar employees from collective arbitration. The Supreme Court had consolidated three cases, Epic Systems Corp. v Lewis, Ernst & Young LLP v. Morris (16-300), and National Labor Relations Board v. Murphy Oil USA, Inc. (16-307). In a 5–4 decision issued in May 2018, the Court ruled that arbitration agreements requiring individual arbitration and prohibiting class action lawsuits are enforceable under the FAA, regardless of allowances set out within the NLRA.

Janus v. American Federation of State, County, and Municipal Employees, Council 31, No. 16-1466, 585 U.S. ___ (2018), abbreviated Janus v. AFSCME, is a landmark decision of the US Supreme Court on US labor law, concerning the power of labor unions to collect fees from non-union members. Under the Taft–Hartley Act of 1947, which applies to the private sector, union security agreements can be allowed by state law. The Supreme Court ruled that such union fees in the public sector violate the First Amendment right to free speech, overruling the 1977 decision in Abood v. Detroit Board of Education that had previously allowed such fees.

Houston Community College System v. Wilson, 595 U.S. ___ (2022), is a United States Supreme Court case involving the First Amendment to the United States Constitution. The unanimous Court held that a local government board member's freedom of speech was not abridged when he was verbally censured by his colleagues.

Southwest Airlines Co. v. Saxon, 596 U.S. ___ (2022), was a United States Supreme Court case related to the scope of the Federal Arbitration Act, in which the Court unanimously held that cargo loaders and ramp supervisors employed at airports are exempt from the Federal Arbitration Act.

Viking River Cruises, Inc. v. Moriana, 596 U.S. ___ (2022), was a United States Supreme Court case related to the scope of the Federal Arbitration Act.

Axon Enterprise, Inc. v. Federal Trade Commission, 598 U.S. 175 (2023), was a United States Supreme Court case related to administrative law.

Sackett v. Environmental Protection Agency, 598 U.S. 651 (2023), also known as Sackett II, was a United States Supreme Court case related to the scope of the Clean Water Act.

Tyler v. Hennepin County, 598 U.S. 631 (2023), was a United States Supreme Court case about government seizure of property for unpaid taxes, when the value of the property seized is greater than the tax debt. A unanimous court held that the surplus value is protected by the Fifth Amendment's Takings Clause.

References

  1. Howe, Amy (May 2, 2022). "Justices add new cases on bankruptcy, overtime pay, and federal civil rights claims". SCOTUSblog . Retrieved May 22, 2022.