Auer v. Robbins

A group of police officers (plaintiffs) brought an action against members of the board of police commissioners (defendants) seeking payment of overtime pay under the Fair Labor Standards Act (FLSA). The defendants claimed that the plaintiffs were not entitled to overtime pay because they were exempt employees under the FLSA. Pursuant to regulations promulgated by the Secretary of Labor (Secretary), one of the requirements to be considered an exempt employee under the FLSA was that the employee earn a specific minimum amount of compensation on a salary basis, i.e., that the employee receive regular predetermined pay at set intervals, with the amount of compensation not subject to decrease because of variations in the employee's quantity or quality of work performed. The plaintiffs claimed they did not meet the salary-basis requirement because the police manual provided that officers' compensation could be reduced for some disciplinary infractions based on their quantity or quality of work. The plaintiffs also claimed that they did not meet other requirements to be exempt employees under the FLSA, including that their duties were not executive, administrative, or professional. The district court found that the plaintiffs satisfied the salary-basis requirement and that most plaintiffs satisfied the duties requirement. The appellate court concluded that all plaintiffs satisfied both the salary-basis and duties requirements and were thus exempt employees under the FLSA who were not entitled to overtime pay. The United States Supreme Court granted certiorari.