Christensen v. Harris County
United States Supreme Court
529 U.S. 576 (2000)
Harris County (defendant), worried it couldn't afford to pay out all employees' accrued FLSA compensatory time, adopted a policy letting supervisors require employees approaching maximum accrued comp time to actually take time off; the county had earlier asked the Department of Labor whether this was permissible, and DOL staff responded in an informal opinion letter saying employers could only compel comp-time use if employees had agreed to that practice in advance. Deputy sheriffs Christensen and others (plaintiffs) sued, arguing the county's mandatory-use policy violated the FLSA; the district court agreed, the Fifth Circuit reversed, and the Supreme Court granted certiorari.
Whether an agency's informal interpretation of its own governing statute, expressed only in an opinion letter rather than through formal rulemaking or adjudication, is entitled to Chevron deference, and whether the FLSA itself prohibits an employer from requiring employees to use accrued compensatory time.