This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
According to Petitioners, the case concerns the interpretation of the companionship services exemption under the Fair Labor Standards Act as amended in 1974.
According to Petitioners, the Department of Labor’s regulations implementing that exemption may be entitled to Chevron deference when they are a permissible implementation of the statute.
The case was submitted to the Court for argument.
Background and question before the Court
Justice Ginsburg asked whether the term “home” refers to the person who employs rather than the person who receives the services.
According to Justice Stevens, justice Stevens inquired whether a statutory provision protects defendants from damages liability if they relied in good faith on the regulation.
Justice Stevens also asked whether the regulation should be given prospective effect.
According to Chief Justice Roberts, chief Justice Roberts noted a conflict among the justices.
According to Justice Scalia, justice Scalia questioned whether an interpretive regulation is a binding regulation and how Chevron versus Skidmore deference should apply.
- [1] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 5
- [2] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 20
- [3] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 21
- [4] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 21
- [5] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 38
- [6] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 41
What each side argues
Petitioners’ Position
Petitioners argue that because the Department of Labor filled in the details through notice‑and‑comment rulemaking, its regulations should receive Chevron deference when they are a permissible implementation of the statute.
Petitioners further contend that if the regulations contain ambiguities or a facial inconsistency, the court should accept the Secretary’s reasonable resolution of those ambiguities.
Respondents’ Position
According to Mr. Becker, respondents assert that the statute creates two types of authority, similar to the tax statutes interpreted in Vogel and Rowan.
According to Mr. Becker, they rely on regulation 552.2(c), which states that only those in Part A define and delimit the scope of the exemption.
What happened at oral argument
Justice Ginsburg asked whether the word “home” refers to the employer rather than the service recipient.
According to Justice Stevens, justice Stevens questioned whether a safe‑harbor provision protects defendants who rely in good faith on the regulation.
Justice Stevens also asked whether the regulation should be given prospective effect.
According to Chief Justice Roberts, chief Justice Roberts noted that the justices were in conflict.
According to Justice Scalia, justice Scalia questioned whether an interpretive regulation is a binding regulation and how Chevron versus Skidmore deference should apply.
- [1] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 5
- [2] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 20
- [3] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 21
- [4] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 21
- [5] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 38
- [6] 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdf, p. 41
What the Court decided
Why it matters
According to Petitioners, the case illustrates how courts may apply Chevron deference to agency regulations interpreting the Fair Labor Standards Act, which can shape employers’ obligations.
Justice Stevens asked whether a safe‑harbor provision protects defendants from damages liability when they rely in good faith on the regulation.
According to Justice Stevens, the discussion about prospective effect raises questions about the future applicability of agency regulations.
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 2eae2d0847105e9a4d10-r1-96b6bcd94461be0f.pdforal argument transcript
Guide generated September 22, 2026. Automated validation accepted this version.