National Automatic Laundry & Cleaning Council v. Shultz
United States Court of Appeals for the District of Columbia Circuit
443 F.2d 689 (1971)
National Automatic Laundry & Cleaning Council (plaintiff) asked the Federal Wage and Hour Administration (defendant) whether certain Fair Labor Standards Act provisions applied to coin-operated laundry employees, and the agency's administrator replied by letter that the provisions did apply, without taking any further enforcement action; National Automatic sued to challenge that interpretation, but the agency argued the interpretation was not reviewable until actually used in an enforcement proceeding, and the district court dismissed the suit on that ground.
Whether an administrative agency's signed interpretation is judicially reviewable prior to its use in an enforcement proceeding.