Retrieved from https://studentshare.org/law/1488630-case-brief-long-island-care-at-home-ltd-v-coke
https://studentshare.org/law/1488630-case-brief-long-island-care-at-home-ltd-v-coke.
Coke is a reversed and remanded case. The rule of this case further involved “filling of a statutory gap”, as per Justice Stephen Breyer’s opinion. Long Island Care had employed Coke as a healthcare attendant for its elderly home services and thus had an employer-employee relationship amid them. Eventually, Coke filed a case against the employer on the grounds of minimum wage and overtime benefits rights as per the Fair Labor Standards Act of 1938 (FLSA) (Cornell University Law School, “Supreme Court”).. Ruling in favor of Long Island, the petitioner, the District Court emphasized Coke to be exempted from the FLSA benefits being employed in the “companionship services” sector giving deference to the Department of Labor’s regulation 29 CFR Section 552.109(a). According to this regulation, employees paid by third-party agencies and not directly by their service users who might be families or households are categorized under the section for “companionship services” and thus, are exempted from the benefits of overtime and minimum wage offered by FLSA.
However, reversing the judgment of the District Court, the US Court of Appeals for the Second Circuit argued that the regulation of “companionship services” was actually a delusion of the statute and thus, was unenforceable on legal grounds. Hence, the regulation was not eligible to obtain lawful deference, either Chevron or Skidmore (OYEZ, “Long Island Care At Home, Ltd. V. Coke”). This particular ruling can be identified with reference to Auer v. Robbins, 519 U.S. 452 (1997) and Christensen v.
Harris County 529 U.S. 576 (2000) that had put a limit rendering Chevron deference and with reference to the case Gonzales v. Oregon, 546 U.S. 243 (2006) that criticized Skidmore deference (Administrative Law Review, “Cases on Deference”). However, the opinion of Justice Stephen Breyer stressed that the regulation, even if under the section “Interpretations”, was legitimate undergoing “full public notice-and-comment procedures”. Breyer argued that the case was a common illustration of defendants “filling a statutory gap” and thus, deference rendered by each court stating that the regulation was “valid and binding” was unlawful.
This made the regulation valid, remanding the judgment of the previous two courts (OYEZ, “Long Island Care At Home, Ltd. V. Coke”). ISSUES The main issues or questions from the case of Long Island Care At Home, Ltd V. Coke, indicated towards the treatment of statutory gap persisting in the regulations included under the section “Interpretations” and its applicability to prove Chevron deference [Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.] (Cornell University Law School, “Chevron, U.S.A., Inc., Petitioner, v.
Natural Resources Defense Council, Inc., et al. American Iron And Steel Institute, et al., Petitioners, v. Natural Resources Defense Council, Inc., et al. William D. Ruckelshaus, Administrator, Environmental Prot”). The issues centered in the case also pointed on the possibility that the Second Circuit might have made a mistake in ruling the regulation as “unpersuasive” and thereby, exempting it from being applicable to Skidmore deference either (OYEZ, “Long Island Care At Home, Ltd. V. Coke”). DECISIONS The decision to the case had undergone three rounds of prosecutions.
First, in the District Court, it was ruled that the “third party regulation was valid and controlling”
...Download file to see next pages Read More