Kasten v. Saint-Gobain Performance Plastics Corp.
Headline: Workers’ oral complaints about wage-and-hour practices are protected: Court holds “filed any complaint” can include spoken complaints, making it easier for employees to raise pay concerns while requiring reasonable notice to employers.
Holding:
- Protects oral employee complaints as covered antiretaliation conduct under the FLSA.
- Makes protection depend on whether a reasonable employer received clear notice.
- Sends the case back for lower courts to decide if notice was sufficient.
Summary
Background
Kevin Kasten, a factory worker, said his employer placed timeclocks so workers were not paid for putting on and taking off protective gear. He repeatedly raised these concerns orally with supervisors and human resources under the company’s grievance procedures. The company later fired him, and lower courts granted the employer summary judgment because they concluded the Fair Labor Standards Act’s antiretaliation phrase “filed any complaint” did not cover oral complaints. The Supreme Court agreed to resolve a split among appeals courts.
Reasoning
The Court asked whether “filed any complaint” can mean spoken complaints as well as written ones. It looked at dictionary meanings, similar statutes, the Act’s enforcement purpose, and long-standing agency practice. The majority concluded the phrase can cover oral complaints, because the law relies on employee complaints to find violations and oral reports serve illiterate or overworked employees. But protection requires fair notice: an oral complaint is covered only if a reasonable employer would understand the employee was asserting rights under the law. The Court gave weight to Department of Labor and EEOC positions and declined to apply the criminal-rule-of-lenity here. The Court reversed the appeals court, vacated its judgment, and sent the case back for the lower courts to determine whether Kasten’s oral statements met the notice standard.
Real world impact
The decision means oral reports about unpaid time can be protected from employer retaliation if they clearly notify the employer of a rights claim. It supports use of hotlines and informal grievance procedures, but leaves lower courts to decide on notice in specific cases. This is not a final ruling on the merits; outcomes may change on remand.
Dissents or concurrances
Justice Scalia dissented, arguing the retaliation phrase should be read to cover only formal complaints filed with a court or agency, not intracompany oral complaints, and he rejected deference to agency views.
Opinions in this case:
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