No. 23-217October Term 2024Decided Jan 15, 2025
E.M.D. Sales, Inc., et al., Petitioners v. Faustino Sanchez Carrera, et al.
The Supreme Court unanimously ruled that employers must prove an employee falls under a Fair Labor Standards Act exemption by a preponderance of the evidence, rather than the higher clear and convincing evidence standard.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jan 15, 2025
- What it's about
The Supreme Court unanimously ruled that employers must prove an employee falls under a Fair Labor Standards Act exemption by a preponderance of the evidence, rather than the higher clear and convincing evidence standard. The case arose when sales representatives sued a food distributor for unpaid overtime, and the employer argued they were exempt as outside salesmen.
Question presented
Is the burden of proof that employers must satisfy to demonstrate the applicability of a Fair Labor Standards Act exemption a mere preponderance of the evidence or clear and convincing evidence?
- Case path
United States Court of Appeals for the Fourth Circuit / Decision released Jan 15, 2025
- Area
Decided Supreme Court case
Documents
Related cases




Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Mar 30, 2026
- Method
- Methodology
Primary materials8
Supreme Court docket 23-217
docket | Mar 30, 2026
Primary case document
Supreme Court document | Mar 30, 2026
CourtListener docket record
docket | Mar 30, 2026
Questions Presented
brief | Mar 8, 2026
Carrera
opinion | Jan 15, 2025
opinion
opinion | Jan 15, 2025
Oral Arguments - Carrera
audio | Nov 5, 2024
Petition
brief | Sep 5, 2023