United States v. Myers
Headline: Court limits overtime pay for customs inspectors by reversing awards for weekday night shifts while affirming Sunday and holiday pay, affecting inspectors and port operations nationwide.
Holding: The Court reversed awards for weekday nighttime work that falls within regularly assigned shifts but affirmed that customs inspectors must receive extra compensation for Sunday and holiday duty.
- Allows collectors to assign night shifts without overtime pay if within regular tours
- Requires extra pay for all Sunday and holiday work regardless of time of day
- Extends overtime rules to bridges, tunnels, and other transport facilities
Summary
Background
Five customs inspectors stationed at the Port of Detroit sued for extra pay for nighttime, Sunday, and holiday work covering September 1, 1931, through August 31, 1937. The inspectors were assigned to eight-hour tours that could fall at any time in a 24-hour day. The Court of Claims awarded pay for both nighttime and Sunday/holiday work; the Supreme Court reviewed that decision.
Reasoning
The key question was whether the statute’s term “overtime services” includes any work between 5 P.M. and 8 A.M. regardless of an inspector’s regular assigned hours, and whether Sundays and holidays get extra pay no matter the time of day. The Court concluded that “overtime” means hours beyond the regular daily tour (the statutory day being 8 A.M. to 5 P.M.), and the collector may assign shifts within the 24-hour period without creating overtime for night work. By contrast, Sundays and holidays are separately covered and carry extra pay regardless of when during the day the work is done. The Court also held the United States, as employer, is liable for sums inspectors earn under the statutes and noted the Tariff Act’s expanded definitions include bridges and tunnels.
Real world impact
The decision reverses nighttime-pay awards when night work is part of a regularly assigned shift but upholds extra pay for Sunday and holiday duty. The case was remanded to the Court of Claims to calculate the inspectors’ recoveries under this rule.
Dissents or concurrances
Chief Justice Stone would have reversed entirely and dismissed the suits, a view the Court did not adopt.
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