Kasten v. Saint-Gobain Performance Plastics Corp., 563 U.S. 1

Kasten sued his employer under the FLSA for retaliation after allegedly being discharged for orally complaining about timeclock placement.
District court granted summary judgment, holding the Act’s retaliation provision does not protect oral complaints.
Seventh Circuit affirmed, holding that ‘filed any complaint’ covers only written complaints to the government, not intracompany oral complaints.
The Supreme Court granted certiorari to resolve whether ‘filed any complaint’ includes oral complaints; there was circuit conflict.
The Court considered statutory text, context, and enforcement concerns, including agency interpretations and historical usage, to determine coverage of oral complaints.
The Court vacated the Seventh Circuit judgment and remanded for further proceedings consistent with its opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 'filed any complaint' cover oral complaints under § 215(a)(3)?	Kasten: oral complaints fall within 'filed any complaint'.	Saint-Gobain: the phrase covers only written complaints to government bodies.	Yes; oral complaints are protected.
Is fair notice compatible with protecting oral complaints under the Act?	Oral complaints provide necessary enforcement flexibility for illiterate or overworked workers.	Notice must be sufficiently formal to avoid undue employer uncertainty.	Fair notice can be satisfied by sufficiently clear and detailed oral complaints.

Scott v. Harris, 550 U. S. 372 (2007) (summary judgment standard applied to disputed facts)
Hagan v. Echostar Satellite, L. L. C., 529 F.3d 617 (CA5 2008) (antiretaliation coverage of oral complaints debated)
Lambert v. Ackerley, 180 F.3d 997 (CA9 1999) (en banc; debates on protected complaints)
NLRB v. Scrivener, 405 U. S. 117 (1972) (protects participation in investigations as protected activity)
MCI Telecommunications Corp. v. American Telephone & Telegraph Co., 512 U. S. 218 (1994) (contextual indications inform term meaning)