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Encino Motorcars, LLC v. Navarro

United States Supreme Court

136 S. Ct. 2117 (2016)

Relevant factsFree

After decades of interpreting the FLSA's vehicle-sales-and-service overtime exemption to cover service advisors like Navarro (plaintiff), an interpretation the industry had come to rely on, the Department of Labor issued a 2011 regulation reversing course with only a summary, conclusory discussion rather than a reasoned explanation for the change; Navarro sued Encino (defendant) for FLSA overtime violations, the district court dismissed based on the exemption, and the Ninth Circuit reversed after granting the new regulation Chevron deference.

IssueFree

Whether an administrative agency's regulation is entitled to Chevron deference if the regulation is procedurally defective.

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