The overtime requirements of the Fair Labor Standards Act (FLSA) do not apply to any employee employed in a bona fide executive, administrative, or professional capacity, as these terms are defined by Department of Labor (DOL) (defendant) regulations. In 1974, the Wage and Hour Administrator (Administrator) issued an opinion letter advising that certain probation officers were exempt from the overtime requirements as administrative employees. In 1988, the DOL issued two additional opinion letters, in which it stated that probation officers were not exempt as executive, administrative, or professional employees. The Taylor-Callahan-Coleman Counties District Adult Probation Department (District) (plaintiff) challenged the two 1988 opinion letters, neither of which was actually addressed to the District. The District argued that the letters were legislative rules that had been improperly put into effect without notice and comment and that they were inconsistent with earlier regulations and the statute. The district court dismissed the case for lack of subject matter jurisdiction, and the matter was brought before a federal appellate court.