Battaglia v. General Motors, Corp.

Battaglia and other employees (plaintiffs) of General Motors Corporation (General Motors) (defendant) brought four separate suits against their employer for monetary damages under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. §§ 201-219, for failure to pay overtime wages. The suits were brought as a result of three 1946 United States Supreme Court decisions involving miners that interpreted “work week” to include underground travel time and other preliminary and incidental activities. Those cases spurred almost two thousand lawsuits from July 1946 through January 1947, seeking more than five billion dollars for unpaid overtime. Congress reacted by passing the “Portal-to-Portal” Act of 1947, 29 U.S.C. §§ 251-62, on May 14, 1947, which, under sections 2(a) and (b), eliminated employer liability under the FLSA for failure to pay employees for the type of preliminary and incidental activities that were the subject of the Supreme Court decisions. Section 2(d) of the Act also removed jurisdiction of federal and state courts over these wage claims, regardless of whether the claims were brought before or after May 14, 1947. The Portal-to-Portal Act became effective while the Battaglia claims were pending in district court. The district court then granted General Motors’ motion to dismiss for lack of jurisdiction pursuant to the Portal-to-Portal Act, and the plaintiffs appealed.