Tennessee Coal, Iron & Railroad Co. v. Muscoda Local No. 123
Encyclopedia
Tennessee Coal, Iron & Railroad Co. v. Muscoda Local No. 123, 321 U.S. 590
(1944), was an important decision of the United States Supreme Court
with regard to the interpretation of the Fair Labor Standards Act
(FLSA). This set a precedent for an expansive construction of the language of the FLSA.
to determine whether time spent by their employees traveling underground to their work sites constituted employment for which compensation was due under the FLSA. The district court found that this transit time was work, and the appellate court affirmed its holding as to travel time.
, held that the miners' travel time constituted "work" under the Fair Labor Standards Act, entitling them to pay for such time. The Court stated that the Fair Labor Standards Act is a “remedial and humanitarian” statute, which “must not be interpreted or applied in a narrow, grudging manner.” Congress intended the Act to mandate either regular or overtime compensation for all work activities.
and Frankfurter
each wrote a short concurrence. Both argued that the determination of the trial court that the miners' travel time was part of their workweek was an issue of fact that should be affirmed unless clear error was present.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1944), was an important decision of the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
with regard to the interpretation of the Fair Labor Standards Act
Fair Labor Standards Act
The Fair Labor Standards Act of 1938 is a federal statute of the United States. The FLSA established a national minimum wage, guaranteed 'time-and-a-half' for overtime in certain jobs, and prohibited most employment of minors in "oppressive child labor," a term that is defined in the statute...
(FLSA). This set a precedent for an expansive construction of the language of the FLSA.
Background
Three iron ore companies filed a declarative actionDeclaratory relief
Declaratory relief is a judge's determination of the parties' rights under a contract or a statute, often requested in a lawsuit over a contract. In theory, an early resolution of legal rights will resolve some or all of the other issues in the matter....
to determine whether time spent by their employees traveling underground to their work sites constituted employment for which compensation was due under the FLSA. The district court found that this transit time was work, and the appellate court affirmed its holding as to travel time.
Decision
The Court, in an opinion written by Justice MurphyFrank Murphy
William Francis Murphy was a politician and jurist from Michigan. He served as First Assistant U.S. District Attorney, Eastern Michigan District , Recorder's Court Judge, Detroit . Mayor of Detroit , the last Governor-General of the Philippines , U.S...
, held that the miners' travel time constituted "work" under the Fair Labor Standards Act, entitling them to pay for such time. The Court stated that the Fair Labor Standards Act is a “remedial and humanitarian” statute, which “must not be interpreted or applied in a narrow, grudging manner.” Congress intended the Act to mandate either regular or overtime compensation for all work activities.
Concurring opinions
Justices JacksonRobert H. Jackson
Robert Houghwout Jackson was United States Attorney General and an Associate Justice of the United States Supreme Court . He was also the chief United States prosecutor at the Nuremberg Trials...
and Frankfurter
Felix Frankfurter
Felix Frankfurter was an Associate Justice of the United States Supreme Court.-Early life:Frankfurter was born into a Jewish family on November 15, 1882, in Vienna, Austria, then part of the Austro-Hungarian Empire in Europe. He was the third of six children of Leopold and Emma Frankfurter...
each wrote a short concurrence. Both argued that the determination of the trial court that the miners' travel time was part of their workweek was an issue of fact that should be affirmed unless clear error was present.
Dissenting opinion
Justice Roberts dissented in an opinion joined by Chief Justice Stone. Viewing the court's interpretation of the FLSA as overly expansive, Justice Roberts emphasized the importance of interpreting what is written in a statute, rather than what the court wishes is in the statute.See also
- Fair Labor Standards ActFair Labor Standards ActThe Fair Labor Standards Act of 1938 is a federal statute of the United States. The FLSA established a national minimum wage, guaranteed 'time-and-a-half' for overtime in certain jobs, and prohibited most employment of minors in "oppressive child labor," a term that is defined in the statute...
- Jewell Ridge Coal Corp. v. United Mine Workers of America
- List of United States Supreme Court cases, volume 321
- List of United States Supreme Court cases by the Stone Court