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Williams v. Central Transport International, Inc.

United States Court of Appeals, Eighth Circuit

July 28, 2016

Glenn Williams, on behalf of himself and all others similarly situated Plaintiff- Appellant
Central Transport International, Inc., et al. Defendants-Appellees

          Submitted: January 12, 2016

         Appeal from United States District Court for the Eastern District of Missouri - St. Louis

          Before LOKEN, GRUENDER, and KELLY, Circuit Judges.

          LOKEN, Circuit Judge.

         The Fair Labor Standards Act (FLSA) provides that employers must pay non-exempt employees at "one and one-half times the regular rate" for time worked in excess of forty hours per week. 29 U.S.C. § 207(a)(1). The FLSA exempts "any employee with respect to whom the Secretary of Transportation has power to establish qualifications and maximum hours of service" under the Motor Carrier Act (MCA). 29 U.S.C. § 213(b)(1) (hereafter, "the MCA Exemption"). Central Transport, LLC, ships freight throughout the United States and is a "motor carrier" subject to the Secretary's MCA jurisdiction. See 49 U.S.C. §§ 13102(14), 13501.

         Glenn Williams brought this action alleging that Central Transport violated the FLSA's overtime requirements when it employed him as a "switcher" at its St. Louis terminal from October 2012 through May 2013.[1] The district court[2] granted Central Transport summary judgment, agreeing that Williams worked as a "loader" of freight in interstate commerce and thus fell within the MCA Exemption. Williams appeals. The question of how Williams spent his time working for Central Transport is a question of fact; the ultimate issue of whether his work activities exempted Central Transport from paying FLSA overtime is one of law. See Icicle Seafoods, Inc. v. Worthington, 475 U.S. 709, 714 (1986); Jarrett v. ERC Props., Inc., 211 F.3d 1078, 1081 (8th Cir. 2000). Reviewing the grant of summary judgment and the district court's interpretation of these federal statutes de novo, we affirm. See McCall v. Disabled Am. Veterans, 723 F.3d 962, 965 (8th Cir. 2013) (standard of review).


         Enacted in 1935, the MCA authorized the Interstate Commerce Commission (ICC) to set the "qualifications and maximum hours of service" for employees of motor vehicle common carriers. 49 U.S.C. § 304(a) (repealed).[3] In 1938, Congress enacted the FLSA, which empowered the Secretary of Labor to regulate the maximum hours of covered employees. See 29 U.S.C. § 207(a)(1). Congress included the MCA Exemption to avoid potentially overlapping jurisdictions. In the following years, the Supreme Court issued a series of decisions interpreting the MCA Exemption; those decisions govern the issue raised by Williams on appeal.

         In United States v. American Trucking Ass'ns, 310 U.S. 534, 553 (1940), the Court rejected the contention of interstate truckers that all their employees are exempt, concluding that the ICC's jurisdiction to regulate maximum hours "is limited to those employees whose activities affect the safety of [motor carrier] operation." In Southland Gasoline Co. v. Bayley, 319 U.S. 44, 47-48 (1943), the Court held that the MCA Exemption applies whenever the Secretary of Transportation has the authority to regulate the maximum hours of motor carrier employees, whether or not that authority has been exercised. Thus, it is irrelevant that the Secretary has never set maximum hours for motor carrier employees such as Williams.

         Before and after enactment of the FLSA, the ICC issued numerous reports and regulations dealing "so thoroughly and expertly with the safety of operation of interstate motor transportation as to entitle them to especially significant weight in the interpretation of [the MCA]." Levinson v. Spector Motor Serv., 330 U.S. 649, 662 (1947). Following the Court's decision in American Trucking, the ICC after extensive hearings ruled that motor carrier drivers, mechanics, loaders, and drivers helpers "perform duties which affect the safety of operation and are therefore subject to the authority conferred [by the MCA] to prescribe qualifications and maximum hours of service." MC-2, 28 M.C.C. 125, 126 (1941).

         In Levinson, the Court upheld the ICC's conclusion that loaders, as a class, affect safety of operation:

The evidence makes it entirely clear that a motor vehicle must be properly loaded to be safely operated on the highways of the country. If more weight is placed on one side of the vehicle than on the other, there is a tendency to tip when rounding curves. If more weight is placed in the rear of the vehicle, the tendency is to raise the front wheels and make safe operation difficult. Further, it is necessary that the load be distributed properly over the axles of the motor vehicle.

330 U.S. at 652 n.2, quoting MC-2, 28 M.C.C. at 134. The Court clarified that the MCA Exemption applies even if a loader does not spend all or even most of his time on safety-affecting activities. To fall within the ICC's (now the Secretary of Transportation's) jurisdiction, it is enough that an employee devote "a substantial part of his time to activities directly affecting safety of operation." Id. at 674, 681 (quotation omitted). In so ruling, the Court rejected the contrary position of the Department of Labor (DOL), appearing as amicus curiae:

[I]t is important to recognize that, by virtue of the unique provisions of [the MCA Exemption], we are not dealing with an exception to [the FLSA] which is to be measured by regulations which Congress has authorized to be made by the Administrator of the Wage and Hour Division, United States Department of Labor. Instead, we are dealing here with the interpretation of the scope of the safety program of the [ICC], under § 204 of the Motor Carrier Act, which in turn is to be interpreted in the light of the regulations made by the [ICC] pursuant to that Act. Id. at 676-77.

         In a companion case to Levinson, the Court held that whether a particular employee falls within an exempt class, such as loader, "is to be determined by judicial process." Pyramid Motor Freight Corp. v. Ispass, ...

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