Battaglia v. General Motors Corp.

1948

Venue: 2d Cir

Facts: Congress has passed the Portal-to-Portal act, which excuses employers from failure to pay minimum wages for time spent at work but not working (i.e., walking to the work site, changing clothes, etc.) prior to 1947. The workers in question had filed for compensation under the Fair Labor Standards Act for just such payments.

Posture: Suits were dismissed. Appeal.

Issue: Does the act deprive the federal courts of hearing this case, and is this a taking?

Holding: Yes and no. Congress's exception power was exercised here in conformity with 5A. Affirmed.

Rule: Congress has the power to give, withold, and restrict jurisdiction of courts other than the supreme court, but it must not do so in an arbitrary or unconstitutional way.

Reasoning: Contracts must be construed in light of the statutes in effect at the time of their execution. These folks had a statutory claim, but it had not ripened into a judgment, so Congress was free to act, and didn't deprive anyone of their rights. If we didn't allow this sort of change, you could proactively contract around pending legislation.

Dicta: Congress may not exercise its commerce power in a discriminatory of arbitrary manner.