Christopher v. SmithKline Beecham Corp.
United States Supreme Court
567 U.S. 142 (2012)
SmithKline Beecham Corp. (SmithKline) (defendant) was a pharmaceutical company that sold prescription drugs. SmithKline hired detailers, also known as pharmaceutical sales representatives, to promote SmithKline products to doctors with the goal of obtaining a nonbinding commitment from doctors to prescribe SmithKline drugs. The pharmaceutical industry had used detailers in this capacity since the 1950s. In 2003, SmithKline hired Michael Christopher and Frank Buchanan (plaintiffs) as detailers. Both plaintiffs were hired based on their prior sales experience. SmithKline trained the plaintiffs to obtain the maximum possible commitment from doctors. The plaintiffs spent approximately 40 hours per week in the field visiting doctors and an additional 10 to 20 hours per week attending events, going over products, and performing administrative tasks. SmithKline did not closely monitor the plaintiffs’ work. In addition to base pay, the plaintiffs received incentive pay based on their sales volumes. Christopher’s average earnings totaled $72,000 per year. Buchanan’s average earnings totaled $76,000 per year. SmithKline did not pay the plaintiffs overtime pay for hours worked in excess of 40 hours per week. The plaintiffs sued SmithKline for overtime pay under the Fair Labor Standards Act (FLSA), 29 U.S.C. § 201, et seq. The district court granted summary judgment for SmithKline. The court of appeals affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Alito, J.)
Dissent (Breyer, J.)
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