Long Island Care at Home, Ltd. v. Coke (2006)
- Docket
- 06-593
- Decided
- 2006-01-01
Summary
Question: 1) Is a regulation found under a subpart headed "Interpretations" still entitled to be given Chevron deference by the courts? 2) Did the Second Circuit err in holding a Department of Labor regulation unpersuasive and thus undeserving of Skidmore deference? Conclusion: Yes and yes. A unanimous Court ruled that the Department of Labor's regulation was "valid and binding" and therefore entitled to all of the deference courts normally give to administrative regulations. The opinion by Justice Stephen Breyer considered the regulation a normal instance of an agency "filling a statutory gap," and rejected each of the lower court's arguments that it was unlawful. The regulation was intended to be legally binding even though it was under a section titled "Interpretations." This was evidenced by the importance of the regulation and the fact that the Department went through full public notice-and-comment procedures. The "Interpretations" heading may have simply referred to that section's more detailed focus, which interpreted the more general regulations of the previous section. Since the regulation was valid and proper, the Court held, the FLSA's "companionship services" exemption continues to apply to workers paid by third-party agencies.