United States v. Rosenwasser
Headline: Minimum wage and overtime rules apply to piece-rate workers; Court reverses lower ruling and makes employers liable for underpaying or overworking piece-rate employees.
Holding: The Court held that the Fair Labor Standards Act covers employees paid by the piece, so employers can be criminally liable for not paying minimum wage or overtime to piece-rate workers.
- Requires employers to convert piece pay to hourly rates to check compliance.
- Makes employers criminally liable for willful underpaying of piece-rate workers.
- Extends minimum wage and overtime protection to many piece-rate industries.
Summary
Background
This case is a direct appeal from a government prosecution against a garment business that paid workers by the piece. The District Court dismissed charges that the employer had violated the law’s minimum wage, overtime, and record-keeping rules, ruling that the law did not apply to piece-rate workers. The central dispute is whether employees paid by the piece are covered by the Fair Labor Standards Act.
Reasoning
The Court asked whether the law’s protections reach workers paid by the piece and whether employers can be criminally liable for violating those protections. It looked at the law’s purpose — to raise low wages and limit long hours — and found no reason to exclude piece workers. The Court relied on the statute’s plain words, which say the law covers “each” and “any” employee and defines “employee” broadly. It said hourly measures in the text are practical tools, not exclusions, and that piece-rate pay can be converted into hourly equivalents to test compliance. The Court therefore reversed the District Court’s dismissal and allowed the prosecution to proceed.
Real world impact
The decision means that many workers paid by the piece in industries like garments are covered by minimum wage and overtime rules. Employers must check whether piece pay meets hourly minimums and must account for overtime, or risk criminal penalties for willful violations. The ruling rejects an implied exemption for piece-rate systems and restores the law’s broad coverage as applied in many industries.
Dissents or concurrances
One Justice, Mr. Justice Roberts, dissented from the majority opinion.
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