Kasten v. Saint-Gobain Performance Plastics Corp.

Background

Kevin Kasten, a former factory employee, says his employer placed timeclocks so workers lost pay while putting on and taking off required gear. He repeatedly told supervisors and human resources about the problem orally. Lower courts granted summary judgment to the employer because they concluded the Fair Labor Standards Act’s antiretaliation phrase “filed any complaint” meant written complaints only, prompting Kasten to seek review.

Reasoning

The Court asked whether “filed any complaint” can cover oral complaints. It looked at dictionary meanings, how similar words are used in statutes and agency rules, and the Act’s purpose of protecting vulnerable workers. The Court gave weight to long-standing agency practice and concluded the phrase can include oral complaints when the communication is clear enough that a reasonable employer would understand the worker as asserting rights under the law. The Court rejected applying the criminal-law rule of lenity here and declined to decide whether complaints must be made to a government agency rather than an employer.

Real world impact

The ruling means that verbal reports about wage-and-hour violations can trigger antiretaliation protection if they give fair notice to a reasonable employer. Agencies may continue or expand hotlines and oral intake. The Court vacated the appellate judgment and sent the case back for lower courts to decide whether the particular oral complaints met the required notice standard.

Dissents or concurrances

Justice Scalia dissented, arguing the statute’s text and context show “filed any complaint” refers to formal filings with courts or agencies, not employee-to-employer objections, and that agency views should not control interpretation.