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E.M.D. Sales, Inc., et al. v. Faustino Sanchez Carrera, et al.

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 21-1897, 21-1924 · judgment July 27, 2023


Decided · January 15, 2025
Pre-decision estimate: 47% cert probability (95% interval 34%–59%)

Before the decision, about 11.3× the 4.1% base rate. The model weighted this up for a petition filed soon after the judgment below, counsel who has won certiorari before, and a circuit split argued in the petition.

Question presented

The Fair Labor Standards Act (FLSA) covers more than 140 million workers and guarantees eligible workers a minimum wage and overtime pay. But the FLSA also contains 34 exemptions from those requirements. Employers do not have to pay overtime to, e.g., bona fide executives, agricultural workers, and outside salesmen. See 29 U.S.C. § 213(a)-(b). The question presented is: Whether the burden of proof that employers must satisfy to demonstrate the applicability of an FLSA exemption is a mere preponderance of the evidence-as six circuits hold-or clear and convincing evidence, as the Fourth Circuit alone holds.

Counsel of record

For petitioner
Lisa S. Blatt
Williams & Connolly LLP

For respondent
Lauren Elizabeth Bateman
Public Citizen

Case

Conference history
Distributed for 5 conferences

Amicus briefs
3 cert-stage · 6 merits
(6 supporting pet./neither)

Argument & decision

Argued November 5, 2024 — Lisa S. Blatt · Lauren E. Bateman. Audio and transcript

Decided January 15, 2025. Opinion by Kavanaugh.

Proceedings

  1. Feb 18 2025
    Judgment Issued.
  2. Jan 15 2025
    Judgment REVERSED and case REMANDED. Kavanaugh, J., delivered the opinion for a unanimous Court. Gorsuch, J., filed a concurring opinion, in which Thomas, J., joined.
  3. Nov 05 2024
    Argued. For petitioners: Lisa S. Blatt, Washington, D. C.; and Aimee W. Brown, Assistant to the Solicitor General, Department of Justice, Washington, D. C. (for United States, as amicus curiae.) For respondents: Lauren E. Bateman, Washington, D. C.
  4. Oct 22 2024
    Reply of petitioners E.M.D. Sales, Inc., et al. filed. (Distributed)
  5. Oct 15 2024
    Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument GRANTED.
  6. Oct 01 2024
    CIRCULATED
  7. Sep 25 2024
    Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed.
  8. Sep 24 2024
    Brief of respondents Faustino Sanchez Carrera, et al. filed.
  9. Aug 20 2024
    Brief amicus curiae of United States filed.
  10. Aug 19 2024
    Brief amici curiae of The Local Government Legal Center, et al. filed.
  11. Aug 19 2024
    Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed.
  12. Aug 19 2024
    Brief amici curiae of National Assoc. of Wholesaler-Distributors, et al. filed.
  13. Aug 14 2024
    Brief amicus curiae of Washington Legal Foundation filed.
  14. Aug 14 2024
    Brief amicus curiae of New England Legal Foundation filed.
  15. Aug 13 2024
    Brief of petitioners E.M.D. Sales, Inc., et al. filed.
  16. Aug 09 2024
    Record received from the United States Court of Appeals for the Fourth Circuit. The record is electronic and is available on PACER.
  17. Aug 06 2024
    Record requested from the United States Court of Appeals for the Fourth Circuit.
  18. Jul 26 2024
    SET FOR ARGUMENT on Tuesday, November 5, 2024.
  19. Jul 22 2024
    Motion to dispense with printing the joint appendix filed by petitioner GRANTED.
  20. Jul 02 2024
    Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioners' brief on the merits is extended to and including August 13, 2024. The time to file respondents' brief on the merits is extended to and including September 24, 2024.
  21. Jun 25 2024
    Motion to dispense with printing the joint appendix filed by petitioners E.M.D. Sales, Inc., et al.
  22. Jun 25 2024
    Motion for an extension of time to file the briefs on the merits filed.
  23. Jun 17 2024
    Petition GRANTED.
  24. Jun 10 2024
    DISTRIBUTED for Conference of 6/13/2024.
  25. May 21 2024
    DISTRIBUTED for Conference of 6/6/2024.
  26. May 21 2024
    Supplemental brief of petitioners E.M.D. Sales, Inc., et al. filed. (Distributed)
  27. May 20 2024
    Supplemental brief of respondents Faustino Sanchez Carrera, et al. filed. (Distributed)
  28. May 07 2024
    Brief amicus curiae of United States filed.
  29. Dec 11 2023
    The Solicitor General is invited to file a brief in this case expressing the views of the United States.
  30. Dec 01 2023
    Rescheduled.
  31. Dec 01 2023
    DISTRIBUTED for Conference of 12/8/2023.
  32. Nov 14 2023
    DISTRIBUTED for Conference of 12/1/2023.
  33. Nov 13 2023
    Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioner.
  34. Nov 13 2023
    Reply of petitioners E.M.D. Sales, Inc., et al. filed. (Distributed)
  35. Nov 07 2023
    Brief of respondents Faustino Sanchez Carrera, et al. in opposition filed.
  36. Oct 12 2023
    Response Requested. (Due November 13, 2023)
  37. Oct 11 2023
    DISTRIBUTED for Conference of 10/27/2023.
  38. Oct 10 2023
    Brief amici curiae of Chamber of Commerce of the United States of America, et al. filed.
  39. Oct 06 2023
    Brief amicus curiae of Washington Legal Foundation filed. (Distributed)
  40. Oct 03 2023
    Waiver of right of respondent Faustino Sanchez Carrera, et al. to respond filed.
  41. Sep 05 2023
    Petition for a writ of certiorari filed. (Response due October 10, 2023)