J. F. Fitzgerald Construction Co. v. Pedersen

Background

An employee, Pedersen, and other workers sued the construction company that hired them to repair abutments and substructures on four interstate railroad bridges after flood damage. They brought the case in New York state court under the federal Fair Labor Standards Act to recover unpaid overtime and matching liquidated damages. After various state-court rulings and an earlier Supreme Court reversal and remand, the trial court entered judgment for the workers and awarded interest from April 1, 1939; the New York courts later affirmed that judgment, including interest.

Reasoning

The Court reviewed two questions: whether the workers were engaged in interstate commerce and whether they could receive interest on the sums awarded under the Act. The Court held that the agreed statement of facts showed the workers were actually repairing parts of interstate bridges and therefore were covered by the Act; petitioner did not contest those facts on remand. But, relying on a companion decision, the Court concluded employees are not entitled to interest on awards under §16(b) of the Act, and it reversed the portion of the state judgment that allowed interest.

Real world impact

The decision means workers who perform repair work on interstate facilities can recover unpaid overtime and equal liquidated damages under the Act, but they cannot collect interest on those awards under §16(b). The judgment stands for wages and liquidated damages but is reduced to remove interest previously awarded.