Drug sales reps' overtime pay
Michael Shane Christopher v. SmithKline Beecham
In brief
The Supreme Court left in place the ruling that Christopher and Buchanan qualified as outside salespeople under the Labor Department’s regulations.
- Where it stands
- Decided
Decided 5-4 · June 18, 2012 · Opinion by Justice Alito
- What it’s about
- GlaxoSmithKline sales representatives Michael Christopher and Frank Buchanan sought overtime pay, disputing that their jobs fit the law’s exception from overtime rules for outside salespeople.
- Who it affects
- Christopher and Buchanan fall within the Fair Labor Standards Act’s outside-sales exception to federal overtime rules.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the Ninth Circuit that they qualified under the most reasonable reading of the Labor Department’s regulations.
The Fair Labor Standards Act exempts qualifying outside salespeople from federal overtime requirements.
Question presented
1. Must Glaxo and the courts defer to the Secretary of Labor's definition of "outside salesman" under the Fair Labor Standards Act? 2. Does the Secretary of Labor's definition of "outside salesman" apply to pharmaceutical sales representatives?
What the Court decided
Holding
Petitioners qualify as outside salesmen under the most reasonable interpretation of the DOL’s regulations. 635 F. 3d 383, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court concluded that the representatives qualified under the most reasonable reading of the Labor Department’s regulations.
The vote
From the opinions
““The question is whether drug company detailers fall within the scope of the term “outside salesman.” In my view, they do not.””
What's next
The Ninth Circuit’s ruling remains in place, and the Supreme Court sent no issue back for another lower-court decision.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
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Audio Recording added: Oral Arguments - Christopher
Opinion added: Christopher
More questions
- What did the representatives do during doctor visits?
- They discussed the features, benefits and risks of Glaxo’s prescription drugs with doctors in assigned territories.
- What did they seek from doctors?
- They sought nonbinding commitments to prescribe the drugs when appropriate.
- How was part of their pay set?
- Part of their compensation depended on sales volume or market share for assigned drugs in their territories.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.