Swift v. AutoZone, Inc.

Summary

The Massachusetts Supreme Judicial Court held that, even before a 2003 statutory amendment, an employer could credit Sunday premium payments toward overtime compensation owed for hours worked over forty in a workweek. The court interpreted G. L. c. 151, § 1A, and G. L. c. 136, § 6 (50), in light of their text and legislative history. It vacated summary judgment for the employees and remanded for judgment in favor of AutoZone.

Holdings

1. Before the 2003 amendment, G. L. c. 151, § 1A, did not prohibit an employer from crediting Sunday premium payments toward overtime compensation owed for work exceeding forty hours in the same workweek.
2. The 2003 amendment expressly permitting crediting was strongly suggestive of the Legislature's original intent to allow the practice and did not establish that crediting had previously been prohibited.
3. No substantial deference was warranted for the agency opinion letter because its interpretation was contrary to the plain language and underlying purpose of the statutes.

Questions Presented

1. Whether, before the 2003 amendment, G. L. c. 151, § 1A, permitted an employer to credit Sunday premium payments toward overtime compensation for hours worked in excess of forty in the same week.
2. Whether G. L. c. 136, § 6 (50), prohibited an employer from crediting Sunday premium payments toward its overtime obligation under G. L. c. 151, § 1A.
3. Whether the administrative agency's contrary interpretation of G. L. c. 151, § 1A, was entitled to substantial deference.

Disposition

vacated