Christopher v. SmithKline Beecham Corp., 567 U.S. ___, 132 S. Ct. 2156 (2012)

Plaintiffs in this case are pharmaceutical sales representatives for SmithKline Beecham whose primary objective was to obtain nonbinding commitments from physicians to prescribe the company’s products. Each week, the employees spent approximately 40 hours in the field calling on physicians and an additional 10 to 20 hours attending events and performing miscellaneous business-related tasks. The employees received a base salary and incentive pay, but no overtime for hours worked in excess of 40 per week because they were classified as exempt outside salespeople. In this lawsuit, the employees claimed they had been misclassified as outside salespeople and that they were entitled to overtime pay. The district court granted summary judgment to the employer, which the employees challenged on the ground that the court had failed to accord controlling deference to the U.S. Department of Labor’s interpretation of the pertinent regulations, which the DOL had announced in 2009 in an amicus brief filed in a similar action. The district court and the Ninth Circuit Court of Appeals rejected the employees’ contention and determined that the DOL’s interpretation is not entitled to controlling deference. The United States Supreme Court affirmed the judgment of the Ninth Circuit.