[SOLVED] Encino Motorcars, LLC v. Navarro Supreme Court

Encino Motorcars, LLC v. Navarro
Supreme Court of the United States, __ U.S. __, 138 S.Ct. 1134, 200 L.Ed.2d 433 (2018).
Background and Facts Encino Motorcars, LLC, owned a Mercedes-Benz dealership in California. Encino employed service advisors whose duties included suggesting repair and maintenance services, recording service orders, following up with customers as the services are performed, and explaining all the work performed, among other functions. Some of Encino’s service advisors, including Hector Navarro, filed a suit against Encino in a federal district court, alleging that the dealership had violated the Fair Labor Standards Act (FLSA) by failing to pay them overtime. Encino argued that the FLSA’s exemption from the overtime-pay requirement applied to Navarro and its other service advisors. The court agreed and dismissed the complaint. The U.S. Court of Appeals for the Ninth Circuit reversed the dismissal. Encino appealed to the United States Supreme Court.
In the Language of the Court
Justice THOMAS delivered the opinion of the Court.
The FLSA exempts from its overtime-pay requirement “any salesman, partsman, or mechanic primarily engaged in selling or servicing automobiles, trucks, or farm implements, if he is employed by a nonmanufacturing establishment primarily engaged in the business of selling such vehicles or implements to ultimate purchasers.” The parties agree that [Encino] is a “nonmanufacturing establishment primarily engaged in the business of selling [automobiles] to ultimate purchasers.” The parties also agree that a service advisor is not a “partsman” or “mechanic,” and that a service advisor is not “primarily engaged in selling automobiles.” The question, then, is whether service advisors are “salesmen primarily engaged in servicing automobiles.”
We conclude that they are. A service advisor is obviously a “salesman.” The term “salesman” is not defined in the statute, so we give the term its ordinary meaning. The ordinary meaning of “salesman” is someone who sells goods or services. Service advisors do precisely that. Service advisors sell customers services for their vehicles. [Emphasis added.] Service advisors are also “primarily engaged in servicing automobiles.”
The word “servicing” in this context can mean either the action of maintaining or repairing a motor vehicle, or the action of providing a service. Service advisors satisfy both definitions. Service advisors are integral to the servicing process. If you ask the average customer who services his car, the primary, and perhaps only, person he is likely to identify is his service advisor. True, service advisors do not spend most of their time physically repairing automobiles. But the statutory language is not so constrained. All agree that partsmen, for example, are “primarily engaged in servicing automobiles.”
But partsmen, like service advisors, do not spend most of their time under the hood. Instead, they obtain the vehicle parts and provide those parts to the mechanics. In other words, the phrase “primarily engaged in servicing automobiles” must include some individuals who do not physically repair automobiles themselves but who are integrally involved in the servicing process. That description applies to partsmen and service advisors alike.
Decision and Remedy; The United States Supreme Court reversed the federal appellate court’s decision and remanded the case. Navarro and the other service advisors were exempt from the overtime pay requirement of the FLSA and thus not entitled to overtime pay.
Critical Thinking:
• Legal Environment: The salesmen, mechanics, and partsmen identified in the FLSA exemption work irregular hours, sometimes away from their principal work site. Service advisors typically work ordinary, fixed schedules on-site. Should the Court have considered these attributes in making its decision in the Encino case? Discuss.
• What If the Facts Were Different? Suppose that the FLSA exemption covered “any salesman or mechanic primarily engaged in selling or servicing automobiles” but not “any partsman.” Would the result have been different? Explain.

Question: Encino Motorcars, LLC v. Navarro Supreme Court