Morris v. McComb

1948-02-02

Headline: Court allows interstate regulator to set driver qualifications and hours, and blocks federal overtime rules from applying to local trucking drivers and mechanics who occasionally haul interstate freight.

Holding: The Court held that the interstate carrier regulator may set qualifications and maximum hours for drivers and mechanics who sometimes handle interstate loads, and therefore those employees are exempt from the federal overtime law.

Real World Impact:

Local drivers and mechanics who sometimes handle interstate loads lose federal overtime protections.
Employers can be regulated by the interstate carrier agency instead of overtime rules.
Limits Wage-and-Hour enforcement for mixed intrastate–interstate cartage operations.

Topics: overtime rules, trucking and delivery, interstate commerce, worker pay protections

Summary

Background

The dispute arose when the federal Wage and Hour Administrator sued the owner of a Detroit-area cartage company that ran local trucking routes and served steel mills. The company employed about 60 people (roughly 40 drivers and 14 garage workers). In 1941 only about 3–4% of its trips involved freight that moved in interstate commerce. The Administrator sought to force the company to pay overtime under the federal overtime law because many employees worked hours that would qualify for extra pay if that law applied.

Reasoning

The Court considered whether the Interstate Commerce Commission (the federal agency that regulates interstate carriers) had authority to set qualifications and maximum hours for drivers and mechanics, even when only a small share of the carrier’s trips were interstate. Relying on earlier decisions, the Court emphasized the nature of the work (its effect on safety in interstate movement), not the small percentage of time spent on interstate trips. The Court held the Commission does have that authority for the class of drivers and mechanics, and Congress made that agency power the test for excluding employees from the federal overtime law.

Real world impact

Because the Commission’s power exists for these classifications, the Court concluded the company’s drivers and mechanics fall under the exemption and the federal overtime rule does not apply to them. The case was sent back to the lower court for further proceedings consistent with the opinion. Employers, unions, and regulators in mixed intrastate–interstate cartage businesses are directly affected by this rule.

Dissents or concurrances

Three Justices dissented, arguing the exemption should be read narrowly; they warned that a tiny amount of interstate work should not strip employees of overtime protections and that the ruling invites evasion of the overtime law.