Walling v. Nashville, Chattanooga & St. Louis Railway

Background

The Administrator of the Wage and Hour Division, U.S. Department of Labor, sued a railroad to stop alleged violations of the federal minimum-wage and record-keeping law. The railroad was accused of failing to pay or keep records for two kinds of trainees: people training to become yard and main-line firemen, brakemen, and switchmen, and people training to become clerks, stenographers, callers, messengers, and similar workers. The District Court denied an injunction as to both groups and found the railroad had been complying in good faith for the clerical trainees. The Circuit Court of Appeals affirmed, with one judge dissenting.

Reasoning

The key question was whether the trainees counted as employees under the law that requires minimum wages and employment records. The Supreme Court accepted the District Court’s unchallenged findings and affirmed. For the clerical trainees, the Court affirmed denial of relief based on the District Court’s finding that the railroad had complied with the law in good faith and did not decide whether those trainees were employees. For the railroad crew trainees, the Court held they were not employees under the law, relying on findings identical to those in a companion case decided the same day.

Real world impact

The decision means the railroad does not have to pay minimum wages to the crew trainees identified in the record because they were found not to be employees under the law. The Court also left unresolved whether clerical trainees generally qualify as employees, but refused to order relief where the employer showed good-faith compliance. This outcome affects railroad employers and the trainees who seek employment in these roles.

Dissents or concurrances

The opinion notes that one judge in the Court of Appeals dissented, but the Supreme Court did not rely on that view and affirmed the lower courts’ rulings.