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O'Connor v. Oakhurst Dairy

(2017)

United States Court of Appeals for the First Circuit - 851 F.3d 69

tl;dr:

A grammatical and fair reading of a Maine overtime law results in the inclusion of a Maine dairy’s delivery drivers within the protections of the law.

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Facts & HoldingO'Connor v. Oakhurst Dairy case brief facts & holding

Facts:Maine has an overtime law that requires employers to pay...

Holding:Holding (Barron): The phrase “packing for shipment or distribution” in...

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O'Connor v. Oakhurst Dairy | Case Brief DeepDive
Majority opinion, author: BARRON, Circuit Judge.
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The legal case involves a dispute between Oakhurst Dairy and its delivery drivers over the interpretation of Exemption F, which exempts certain employees from overtime pay. The United States Court of Appeals for the First Circuit concluded that the exemption's scope is unclear and must be interpreted narrowly in favor of the drivers. The Court found that the District Court's decision was erroneous as it did not consider the ambiguity in the exemption's language. The Court applied canons of linguistic conventions to understand the meaning of the word "distribution" in the context of the exemption as a whole and concluded that Oakhurst's argument that "distribution" is a separate exempt activity is not persuasive. The Court considered the parties' arguments about the exemption's purpose and legislative history to determine the legislative intent and found that Oakhurst's argument is not supported by any directly relevant text or legislative history. The grant of summary judgment was reversed, and the case was remanded for further proceedings.

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