Kasten v. Saint-Gobain Performance Plastics Corp.
563 U.S. 1
SCOTUS2011Background
- Kasten sued his former employer Saint-Gobain Performance Plastics Corp. under the Fair Labor Standards Act (FLSA) antiretaliation provision, alleging he was discharged after orally complaining about the location of time clocks.
- The district court granted summary judgment to the employer, relying on a view that the statute protected only written complaints.
- The Seventh Circuit agreed, holding that the antiretaliation provision did not cover oral complaints.
- This Court granted certiorari to decide whether the phrase “filed any complaint” includes oral complaints within the Act’s protection.
- The Court ultimately held that oral complaints can be protected, rejected the Seventh Circuit’s narrow reading, and remanded for further proceedings on notice requirements.
- The majority emphasize the remedial nature of the Act and interpret the term to include oral complaints where they provide clear notice of asserted rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether oral complaints fall within ‘filed any complaint’ | Kasten—oral complaints are protected | Saint-Gobain—only written complaints to government bodies are protected | Yes, oral complaints are protected. |
| Whether an oral complaint satisfies the notice requirement | Oral notice can reasonably inform employer of asserted rights | Oral complaints may create uncertainty about whether a true complaint was made | Oral complaints can meet the notice standard. |
Key Cases Cited
- Dolan v. Postal Service, 546 U.S. 481 (2006) (contextual reading of statutory terms; interpretive framework cited by Court)
- NLRB v. Scrivener, 405 U.S. 117 (1972) (protection extends to participation in investigations; not limited to formal filings)
- Burlington Indus., Inc. v. Ellerth, 524 U.S. 742 (1998) (grievance procedures; enforcement context relevant to anti-retaliation)
- Skidmore v. Swift & Co., 323 U.S. 134 (1944) (agency views with persuasive effect; not controlling unless supported)
- United States v. Mead Corp., 533 U.S. 218 (2001) (deference framework for agency interpretations; informs weight given agency views)