Auer v. Robbins (1997) — Deference to Agency Regulations

Case Identification

Case name: Auer v. Robbins Court: Supreme Court of the United States Year: 1997 Citation: 519 U.S. 452 Claim Presented The petitioners challenged the Department of Labor's interpretation of its own regulation under the Fair Labor Standards Act regarding whether certain employees qualified for the executive exemption from overtime requirements. The dispute centered on whether public sector employers could apply different criteria than those used by private employers when determining exempt status.

Authority Cited 29 C.F.R. § 541.2 (Department of Labor regulation defining executive exemption) Fair Labor Standards Act, 29 U.S.C. § 201 et seq. The Court addressed the agency's interpretation of its own regulatory language.

Court's Analysis The Court examined whether the Department of Labor's interpretation of its regulation was controlling. The Court stated that an agency's interpretation of its own regulation is "controlling unless 'plainly erroneous or inconsistent with the regulation.'" The Court found the regulation at issue was ambiguous regarding whether different standards could apply to public and private sector employees. The Court concluded that the Department's interpretation, which permitted salary-basis distinctions for public employers, was a reasonable construction of the regulatory text. The Court determined that because the regulation's language did not clearly resolve the interpretive question, deference to the agency's reading was appropriate.

Disposition The Court of Appeals decision was affirmed. The Department of Labor's interpretation of its regulation was upheld.

Procedural Outcome The agency's interpretation of 29 C.F.R. § 541.2 was sustained. The matter was resolved in favor of the respondents.

Archival Note This entry documents the judicial record in Auer v. Robbins as preserved in the official reports. The decision addressed judicial deference to an agency's interpretation of its own regulations and clarified the standard governing such review as reflected in the Court's disposition.