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Helix Energy Solutions Group, Inc. v. Hewitt

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Supreme Court of the United States
Helix Energy Solutions Group, Inc. v. Hewitt
Term: 2022
Important Dates
Argued: October 12, 2022
Decided: February 22, 2023
Outcome
Affirmed
Vote
6-3
Majority
Elena Kagan • Chief Justice John Roberts• Clarence Thomas • Sonia Sotomayor • Amy Coney Barrett • Ketanji Brown Jackson
Dissenting
Neil Gorsuch • Brett Kavanaugh • Samuel Alito

Helix Energy Solutions Group, Inc. v. Hewitt is a case that was decided by the Supreme Court of the United States on February 22, 2023, during the court's October 2022-2023 term. The case was argued before the court on October 12, 2022. The court affirmed the decision of the United States Court of Appeals for the 5th Circuit in a 6-3 ruling, holding that Michael Hewitt was not an executive exempt from the Fair Labor Standards Act’s overtime pay guarantee; daily-rate workers, of whatever income level, qualify as paid on a salary basis only if the conditions set out in §541.604(b) are met. Justice Elena Kagan delivered the majority opinion of the court. Justice Neil Gorsuch and Justice Brett Kavanaugh filed a dissenting opinion, joined by Justice Samuel Alito.[1][2] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Michael Hewitt was a supervisor for Helix Energy Solutions Group's (Helix) offshore oil and gas operations from 2015 to 2017. During that time, he earned more than $200,000 per year through a daily rate of at least $963. Hewitt filed a lawsuit against Helix, claiming he was entitled to overtime pay under the Fair Labor Standards Act (FLSA). The district court ruled he was exempt from overtime pay. On appeal, the 5th Circuit ruled that he was not exempt. Helix appealed to the U.S. Supreme Court.[3] Click here to learn more about the case's background.
  • The issue: The case concerned the FLSA and 29 CFR § 541.601, which states that certain high-earning employees are exempt from overtime pay.
  • The questions presented: "Whether a supervisor making over $200,000 each year is entitled to overtime pay because the standalone regulatory exemption set forth in 29 C.F.R. §541.601 remains subject to the detailed requirements of 29 C.F.R. §541.604 when determining whether highly compensated supervisors are exempt from the FLSA's overtime-pay requirements."[3]
  • The outcome: Michael Hewitt was not an executive exempt from the Fair Labor Standards Act’s overtime pay guarantee; daily-rate workers, of whatever income level, qualify as paid on a salary basis only if the conditions set out in §541.604(b) are met.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 5th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • February 22, 2023: The U.S. Supreme Court affirmed the U.S. Court of Appeals for the 5th Circuit's ruling
    • October 12, 2022: The U.S. Supreme Court heard oral argument.
    • May 2, 2022: The U.S. Supreme Court agreed to hear the case.
    • January 7, 2022: Helix Energy Solutions Group, the petitioner, appealed to the U.S. Supreme Court.
    • September 9, 2021: The 5th Circuit reversed the lower court's ruling and remanded the case.

    Background

    Michael Hewitt worked as a supervisor for Helix Energy Solutions Group's (Helix) offshore oil and gas operations from 2015 to 2017. He lived on the vessel for 28 days at a time, working 12 hours each day. During that time, he was paid a daily rate ranging from $963 to $1,341, earning over $200,000 annually. Helix eventually fired Hewitt for performance issues, after which Hewitt filed a class-action lawsuit against the company. Hewitt claimed he was entitled to overtime pay under the Fair Labor Standards Act (FLSA).[3]

    Helix argued Hewitt was not exempt from overtime pay because he was a "bona fide executive, administrative, or professional employee" under 29 U.S.C. §213(a)(1). The U.S. District Court for the Southern District of Texas agreed, ruling Hewitt was exempt from overtime pay because he was paid the same baseline day rate no matter how many hours he worked on the vessel. Hewitt appealed to the U.S. Court of Appeals for the 5th Circuit. A three-judge panel of the 5th Circuit reversed the district court's ruling. Then, sitting en banc, the court ruled in a 12-6 decision that Hewitt was not exempt from overtime pay.[3]

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    “ Whether a supervisor making over $200,000 each year is entitled to overtime pay because the standalone regulatory exemption set forth in 29 C.F.R. §541.601 remains subject to the detailed requirements of 29 C.F.R. §541.604 when determining whether highly compensated supervisors are exempt from the FLSA's overtime-pay requirements.[5] ”

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    The court affirmed the decision of the United States Court of Appeals for the 5th Circuit in a 6-3 ruling, holding that Michael Hewitt was not an executive exempt from the Fair Labor Standards Act’s overtime pay guarantee; daily-rate workers, of whatever income level, qualify as paid on a salary basis only if the conditions set out in §541.604(b) are met. Justice Elena Kagan delivered the majority opinion of the court. Justice Neil Gorsuch and Justice Brett Kavanaugh filed a dissenting opinion, joined by Justice Samuel Alito.[1][2]

    Opinion

    “ Congress enacted the FLSA to eliminate both “substandard wages” and “oppressive working hours.” Barrentine v.

    Arkansas-Best Freight System, Inc., 450 U. S. 728, 739 (1981). The statute addresses the former concern by guaranteeing a minimum wage. See 29 U. S. C. §206. It addresses the latter by requiring time-and-a-half pay for work over 40 hours a week—even for workers whose regular compensation far exceeds “the statutory minimum.” Overnight Motor Transp. Co. v. Missel, 316 U. S. 572, 577 (1942); see §207. The overtime provision was designed both to “compensate [employees] for the burden” of working extra-long hours and to increase overall employment by incentivizing employers to widen their “distribution of available work.” Id., at 578. Employees therefore are not “deprived of the benefits of [overtime compensation] simply because they are well paid.” Jewell Ridge Coal Corp. v. Mine Workers, 325 U. S. 161, 167 (1945). The FLSA, however, exempts certain categories of workers from its protections, including the overtime-pay guarantee. The statutory exemption relevant here applies to “any employee employed in a bona fide executive, administrative, or professional capacity . . . (as such terms are defined and delimited from time to time by regulations of the Secretary [of Labor]).” §213(a)(1). Under that provision, the Secretary sets out a standard for determining when an employee is a “bona fide executive.” If that standard is met, the employee has no right to overtime wages. [5]

    		”
    —Justice Elena Kagan[8]

    Dissenting opinion

    Justice Neil Gorsuch

    “ Respectfully, I would dismiss this case as improvidently granted. After successfully petitioning the Court to decide

    how §541.601 relates to §541.604, Helix Energy assured us that “the flaw in the decision below has nothing to do with the salary-basis test” in §541.602. Brief for Petitioners 27. I might excuse that disclaimer as a mere rhetorical flourish if Helix Energy’s briefing nonetheless “made clear” the “importance” of §541.602 to this case. Ante, at 8, n. 3. But it did not. The company devoted only about two pages to the issue in its opening brief. Brief for Petitioners 25–27. On reply, Helix Energy went so far as to criticize Mr. Hewitt for trying to “change the subject” from how §541.601 and §541.604 interact to whether §541.602 is satisfied. Reply Brief for Petitioners 3. In these circumstances, I would not reach out to address the operation of §541.602—a question we never granted certiorari to decide, one on which we have received little briefing, and one Helix Energy even assured us we need not decide. [5]

    		”
    —Justice Neil Gorsuch[9]

    Justice Brett Kavanaugh

    “ Michael Hewitt earned about $200,000 per year as a supervisor for Helix, a firm that provides services on

    offshore oil rigs. After being fired, Hewitt sued Helix under the Fair Labor Standards Act and sought hundreds of thousands of dollars in retroactive overtime pay. The Court today rules for Hewitt. I respectfully dissent. Unlike the Court, I would hold that Hewitt was a “bona fide executive” for Helix and therefore not entitled to overtime pay. [5]

    		”
    —Justice Brett Kavanaugh[10]

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 U.S. Supreme Court, Helix Energy Solutions Group v. Hewitt - "Certiorari to the United States Court of Appeals for the Fifth Circuit," accessed February 23, 2023
    2. ↑ 2.0 2.1 SCOTUSblog, Helix Energy Solutions Group, Inc. v. Hewitt accessed February 24, 2023
    3. ↑ 3.0 3.1 3.2 3.3 U.S. Supreme Court, Helix Energy Solutions Group v. Hewitt - "Petition for a writ of certiorari," accessed May 2, 2022
    4. ↑ U.S. Supreme Court, Helix Energy Solutions Group, Inc. v. Hewitt - "Questions presented," accessed May 2, 2022
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 12, 2022
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 12, 2022
    8. ↑ U.S. Supreme Court, Helix Energy Solutions Group v. Hewitt - "Certiorari to the United States Court of Appeals for the Fifth Circuit," accessed February 23, 2023
    9. ↑ U.S. Supreme Court, Helix Energy Solutions Group v. Hewitt - "Certiorari to the United States Court of Appeals for the Fifth Circuit," accessed February 23, 2023
    10. ↑ U.S. Supreme Court, Helix Energy Solutions Group v. Hewitt - "Certiorari to the United States Court of Appeals for the Fifth Circuit," accessed February 23, 2023
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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