# Brief for Petitioner — Kennedy v. Silas Mason Co. > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386406_0028%3A03 ## Record - **Collection:** Supreme Court brief - **Document type:** Brief for Petitioner - **Published:** January 1, 1948 - **Citation:** 334 U.S. 249 ## Text shy “OCTOBER TERM, 1 1947 * 15 — 4 > 2 Py * ö 25 . . 4 ee N 590 aa = —— _ Petition . vermis. .:SILAR MASON COMPANY, 5 on Writ of Corticrari to the United” States Cem o it ume tor Gn Fitch den wits 8 "© ORIGINAL BRIEF OF PETITIONERS. _ . wt V. 7 . 5 3 are | *: LEONARD ) LLOYD LOCKARD 5 „Aten for — —— 2 cg. SHREVEPORT. LOUISIANA = 75 8 8 . s 9 3 25 — the Court Blow. 5 AJuriscketion of this Court — — 3 8 ific 1 of “ei OS Summary of Argument © Specfieation of Err No: SERS - Respondent an Independent 1 Not a Mere Agent of the Government _ Respondent Did Mot Disclose Ite Principal 8 N Seien of Rrror No. 2 3 . Jud 2, 100 —— 3 | Spbeification of Erer No. 3 F ; - Petitioners Produced for Commerce War Not Negation of Commeres Commerce Need N. Be Commercial—_ Made’ 8 6 Congress Intended Coverage and 5 Policy ‘Requires ree — ry 5 ministrative Not Significant 8 Speeittestlon of Error No. 4 5 at ae 1s . See Appendix “A 2 : = : * n . wks 4 That Procurement of Munitions Was Ad. . 9. 2 * 4 2 X INDEX or AUTHORITIES. 5 Page No. Alabama v. King & bees 314 US. 1; 97 L. : d. 8. dnn J4/44/ſJ%%/ ĩͤ .. Am. Jur. 27, See JI, p. 402 Ff Am. Jur. 27, Sec. 16, p. 497. ffn. Ashley Co. v. Bradford, 109 La. 642; 28 So. 684 86 Atlas Fence Co., 61 N. LR. B. 984.586 — e Bell v. Porter, 159 F. (2d) 117 1 2.2328 i FBreakwater v. Us, 0b u 10 "Brooke v. U. S., 267 U.S. 482; 45 S. Ct: 345; 87 5 I 1407; 69 L. Ed. 69. a ae = Brown Shipbuilding Co., 57 N. LR. B. 826, 328 3°: : __ Brown v. Volkening, 64 N.Y. 76.80 : 36 | Bickstaft v: McKinley, 808 U.S. 358; 84 1. 2.14. 15 5 geen b. S., 242 US. 470; 37 S. Ct. 1922 1. L. Ed. 443 LRA. 1917F, 502; Ann. 2 Cas. 1917B, 1168 — o | Carbide & Carbon Chemical Corp'n, 73 NLR. “fo? Kee B. 184-5 ee. . Casement & Co. v. _ Brown, 148 Os. 617; 87 L. 5 d. 582 15 Champion v. 18 U 821; 23.8. Ct 821; r e. g toe = isi -- CLT: 3 vhm Garage, 86 Pac. 2d) N ; 247 — Clyde v. Broderick, 144 F. (2d) $48. 23 Curry v. U. S., 314 US. 14; 86 L. Ed — 2, 10, 8 Dollar Savings Bank v. US, 86 U.S. 27 — 7 82 Ellis v. U.S., 206 U.S. 246 51 L. Ed. 104 | 19 Edwards v. E 8 31 Us. 160; 62 8. = 5 164; L. Ed. 119 22 te 0 Oben No. 9801. . vee Fleming v. Atlantie Co., 40°F. Supp: 65⁴ 3 5 Fleming v. Gregory, 36 F. Supp. 776. — 9 70 nee v. Hawkeye Pearl Button” Co., 113 F. : (2d) 52 5 Ford v. Williams, 21 Howard 287; 161 E Gibbons v. Ogden, 9 Wheat. 1; 6.L. Ed. 23. 5 v. U.S., 297 US. 124; 56 S. Ct. 895; eg Ed. 522 wast Gordon v. U.S., $1 Ct: G. 254 Harris v. Paul, 174 N. E. 615 "-Helena-Glendale Ferry Co. v. Walling 182 F. 24) 616 4 “Hoke v. v. 227 U.S. 808; 88 S. Ct, 281; 57 L. Ed. 523; 43 L. R. A. NB 906; Ann. Cas. 1918E, 905 House Resolutions Nos. 6617, 6689, 6790, 6792, 6795, 6796, 6814, 6823, 6826, 6835, 7064, 5 7781 of 77th Congress House Resolution No. 992 of 78th Conress._ oa Jackson v. Northwest Air Lines, 75 F. Supp. * 1 5 ‘Littleton v. Roberts, 187 S. E. 349 ee, v. Trans. Co., 39 F. Supp. a Moehl v. E. I. du Pont de Nemours Co. 12 Labor Cases, Par. 63, 545 eure Nash v. Towne, 5 Wall. 689; 18 L. Ed. 527 — National cm A Deposit. Co, Co. v. Stead, 232 U. 8. N 583 58 L. NLRB. v. Carroll, 150 f. (2a) 457 N. LR. B. v. Nee 600; 88 Shue L. Ed. 1014 * ‘Atty. Gen’l. (012) 688 : 6 Appendn ee an 31 * * Otc Sibu Conn lun „ 19261034 — oe Overnight Motor Trans. Co. v. Missel, 19 US. ee 8 —— . 8 en Dairi Milk Control Comm. 1; O61. Ed 48. - 21 eae ee ae. Sea re. Ss 5 e Amer. ‘Law Inst. = Neid v. Colorado, 187 U.S. 187; 28 8. Ct. 525 417 1. Ed. 108 f Reynolds Corp'n, 74 N LR. B. No. 248 Roland v. United Air Lines, 75 F. ‘Supp. 25. 5 * n v. Mecnib 3 : 3 8. Ct. 1473. a Sdnate Bills No ion 2878, 2884,, 0 77th Con : Senate Bills Nos| 190, 237, 78th on er a i e 258 U.S. 495; 66 . Swift & Co. v. U,. 196 U.S. 278. . - Swisher v. U. S., 57 Ct. Cl. 123 a 5 Storey on “Agency”, Sec. 267. L Thompson v. Daugherty, 40 F. Supp. 279. Timberlake v. Da 4 Zimmerman 49 F. Supp. 2 EECA - - Unithum v. Day Rime; ioe eet 235 Ta, 298; 10 N. W. 24 28 —— 24,88 United States C 42 N. L. R.B. 191, 1 — rare 23 US. v. Darby Lumber Co., 312 U.S. 100 10 US. v. Driscoll, 96 U.S. 421; 24 L. Ed. 847 11, 12 28 — 95 2 . 2 8 38 NS A SBR ' us 3 . — ——— — — f 23 ° ‘ d ö US: v. Green, 4 Mason 427 325, 826) . a US. v. Hoar, 2 Mason 311. US. v. Hill, 248 U.S. 420% 39 8. Ct. 148; 63 I. Ed. 887 U.S. v. Hughes, 26 Fed. Cases 297 US. v. Coun Allegheny 5 322 U.S. 1 88%. Ed. 1209. — ou US. v. Southeastern Underwriters’ Ass’n ma 322 U.S. 583; 88 L. Ed. 1440 8, 21 U.S. v. Sim m, 262 US 466; 40 S.-Ct. 364; Bs „ 10 KAL. R. 510 . 22 Walling v. Haile * Mines, 186 F. (2d) 12 28 Ww Jacksonville Paper Co. “3 ee! 564; 87 L. gland So Vd Walling V. Patton-Tulley, 134 F. (2d) 945.— 224, 32 Weber v. Freed, 289 U.S. 324; 36 S. Ct. 131: 0 L. Ed. 308; Ann. Cas. 1916C, — 22 3 chouse Elec. & · Mfg. Co. ae 1 LKB. 404, 412 2³ > — Srarurks ‘ crren: Le Act of ns 1940 (Pub. No. 703, 76th Con- 8 Stat. 712, U. S. C. A. 5, 189 (a) 92 if Lend-Lease, 20 U.S. C. A., p. 411-423 40 Judicial Code, 240 (a), 28 U. C. A. See. $47. te a National Labor Relations Act (49.Stat. L. 499), 2 ö Chap. 372, 29 U. S. C. A., Sec. 151, et seg 2 23 Fair Labor Standards Act (US.C.A; 29, Sec. : 90%, & eeg) 8, 17, 6, % Eight-Hour Law, ete., (40 USCA. 221. „ a: 5. OCTOBER TERM, 1947 e 890 on Writ of Certurafi to the United States Cireult Congt of Are. for the Fifth Cireuit ö 3 BRIEF or PETITIONERS. | ‘ln: soe ela adh. a kG aataiaaes granted by this Honorable Court to review the final judg- ment in a elvil case of the United States Cirouit Court of . e for the Fifth Cireuit. N "OPINION OF THE | corr BELOW The original judg judgment of the Fifth Cireuit Court ae An was entered . 12th, 1947 . and 4 . rehearing was 0 without opinion, January un 1048 (R. 260). _ The opinion is reported in 164 f. a 1016. : ‘ — OF THIS COURT. : Jurisdiction was invoked under Séction 240(s) 4 the Judicial Code, as amended (28 U. S. C. A. Section 347). . Jurisdiction was urged: (1) Because of the paramount public’ importance of the issues raised, requiring inter- pretation of provisions of the Fair Labor Standards Act involved in a ‘multitude of cases now pending in the lower | federal eourts; (2) because of the conflict between the ~ decision of the Seventh Circuit Court of Appeals, in BELL „ ve. PORTER, 159 F. (ad) 117, and the decision below; __KING & , $14 US. 1; BUCKSTAFF CO. », _'. McKINLEY, sds U.S. 358; CURRY v. UNIFED | Sars, 814 U.S. 14; PENN ‘DAIRIES . MILK CON- - . PROL.COMM., $18 U.S. 261. | ee Seamuig tho etav bs 00 plainly itt: to Seite il he State apa the Ray of te Court doversies Gis | a 0 =: „. Sir 885 ‘JACKSON ». NORTHWEST AIR LVs =F. od 945. ‘See also UMTHUM v. DAT & ZIMMER- ear MAN. INC., 85 Ia, 298, 3 10 N. W. 2d 26. a 20, bees words are teed: “ ‘employee’ includes any in- ee 8 dividual employed by amemployer”. The word “any” is : a 1 US. 664, 87 L. Ed. 460, Where it was held that the Act’ 5 3 heavy. burden of persuasion. and must a Bor rox co, 118 F. 2d 62. Here, neither t the letter r nor thes yy epirit : admite the attempted exemption. \ ‘a 75 F. Sepp. 82; LI IVG v. PATTON-TULLY co. In the definition. of “employ . A all-inclusive, and it certain ‘forecast the holding ofthis Court in WALLING u. JA KSONVILLE PAPER CO., 7 was intended to extend to the utmost reach of interstate 85 i Ne ee — is” remed den aiming exemy:.. show themsclves excluded by both the letter and the spirit- | at the Act. HELENA GLENDALE FERRY CO. v. WAL-~ LIN d. 158 F. 2d'616;. FLEMING v. HAWKEYE PEARL 9 “Unless the Fair Labor. Standards ‘Act: be “emaseu . - lated to nothing, it must be held to apply to, contractors ne during’ the last war, and now, produce goods for the bDutted States in the conventienal way. This much was > oe - eanceded by the court below-in the ube of this language 4 It the defendant is engaged on this contract in the bus ‘hess of ‘manufacturing munitions -of- war, either as 3 A. ee n proposition, or under a contract by which it agree! ~ ‘to produce and sell to the government either at a fixed 85 V * ° Spree W | 285. are of the opinion that it would come within the’ Fair. : Labor ‘Standards Aet“. . What ‘difference can Mee be, emily; in the — conditions of these petitioners here, making mun- itions for the United States government under u cost plus e “ ee fixed fee contract, as compared to those workers supply- ing goods for the United States. in time of war or peace, such as the’ producers. of trucks; oils, steel, and any other kinds of commodities? Vnto ward bonsequences will ent if this * tion bee the ordinary contractors and “cost plus a fixed fee contractors is adjudged, and. between employees ies of the two kinds of contractors. What: it means is, that workers for th two types of contractors, although they : may be wor ng toward the same end, under the some con- : _ ditions, and e the aame thing, for the army or the g government, generally would be, quoad their employers, : under different requirements as to the-minima of wages and maxima of hours. There is no valid reason for tis ies ee distinction. J udge Hutcheson, in his dissent . aptly . a states what we seek hene to protray: A ask upon 1 What permissible theory can it ie claim- 3 ed that appellants are not covered here, when it is ceonceded that had they been working for a private plant which made munitions for sale arid delivery to the United States for war, they, would haveybeen. The munitions in both cases would be for purpose of war and not for ordinary trade, but in both cases they would have been produced for transportation from a . to N place outside thereof.” : os — 4 imam Sr pt — — plus a fixed fee contracts rested in the fact of advancing ~ costs, the policy of cost plus afixed fee contracts was in . auguratsd. THE GOVERNMENT‘ OF THE UNITED . stint? Why did not the government manifest, me * CONCEDEDLY, HAD THE BENEFIT OF THE ACTS. STATES CERTAINLY DID NOT RESORT TO THIS DEVICE TO SAVE MONEY! Judge Sibley characteriz- ._ ed the cost plus a fixed fee method as “the ‘business folly of making cost plus a fixed fee contracts”. 9 i "Here was the governmént, quite willing to pay out extra money in order to get supplies. Could it be that the . governinent was partisan in its generosity and was ready niggardly attitude toward employees of its other class of | peaermesting the opinion below, and the opinions dk. other lower courts arriving at a similar result, is a notion that these acht“ hape a touch of the immoral and the m patriotic — that they are an attempted gouge of the gov- ‘ernment. BUT ALL THAT ‘PETITIONERS: SEEK | HERE IS AN EQUALITY OF HOURS*AND. WAGES — * WITH OTHER EMPLOYEES OF CONTRACTORS FOR — HE GOVERNMENT, DURING WARTIME, WHO, - py re a ; tractors to make flat bids on government projects. To in- dure the contractor against this extra hazard of advancing 27 3 6 hides, a 2 thousand other commodities. These commodities mee used for WAR, and were as necessary a6 were, anten “Surely the Court can look through mere form, _ method, labels, or apparatus, to the reality of this situ - “tion. Nomenclature is not controlling. That was demon- strated in this Court's recent holding in RUTHERFORD 9 \ FOOD CORPORATION v. McCOMB, 320 U.S. 9 67 S. Ct. 1478, decided ‘June 10, 1047. Said ‘the Court there: i pe dead \ he Fair Labor Standards Act was passed by Congress to lessen, so far as seemed then practicable, the distribution in “commerce of goods produced under sub-normal labor conditions. An effort to eliminate low wages and long hours was the method chosen to free commerce: from the interference aris- ing from production of goods under conditions that Ra were detrimental to the health and well-being of - worker. * Where the work done, in its essence, follows the usual path of an employee, putting on an ‘i t contractor’ label does not take the. =e werhak the protection of the Act." 5 \ _(Emphasis ours) 8 | Congreas Intended Coverage and Policy Requires It : "When this Act was passed in June, 1938, war, ona major scale, was in the offing. , If not foreseen, at least , "the possibility of war was known to Congress, in view of | our repeated experience with it. But, if war was not an- ticipated or taken into account, still Congress knew that the government had, from time immemorial, been making contracts with, and purchases from, private contractors, © 0 — — a 2 “edu of them cost plus a fired * (see UNITED STATES v. “DRISCOLL, .supra). But the Act makes no exemption — for employees of contractors for the government, of any 5 kind whatsoever, whether conventional or cost plus a fixed fee. How then can the Court, as was done below, find a distinction between the two classes of contractors, where Es + the Act makes none and history points to none? | . „ When the wür did come, with the expanded activi- . —— that did not cause Congress to amend this Act, although individual Congressmen thought it should be‘ amended. We are informed, by the amicus — curiae brief of the Department of Labor filed in the court below, that eighteen bills or resolutions were introduced ae in Congress, locking to the suspension of the Act during | the war (Senate Bills Nos. 2232, 2873 and 2884, and House Resolutions Nos. 6617, 6689, 6790, 6792, 6795, 6796, 6814, 6823, 6826, 6835, 7054 and 7731, of the 77th Congress, 24 3 oa Session; dar Bill Nin 180 and in and Hone Bo lution No. 992 of the 78th Congress, 1st Session) none of which were passed. Obviously; such amendments were un- necessary, unless applied to the large group of people who were warking for cost plus a fixed fee contractors. Additionally, se clan a coon’ ©. ey have this view — the coverage of the Act — because in the Portal to Portal Act of 1947 (Public Law 49, 80th Congress, Chap. 52) there is set forth, in Section 1, the Congressional : finding that the ‘cost to the government, under the Fair . labor Standards Act, required the Congress, to act; aud = the Judiciary Committee, im its 98 on this bill, referred : ree ‘ es: o r \\ wv | 5 ce : 29 to the fact that expenditures by the government for sup- plies, through the medium of cost plus a fixed fees con- " tractors, amounted during the war to 840, 000, 000, 000. Accordingly, Congress, both during and after the war, + 885 adhered to the view that the Act applied to cost plus a fixed fiee contractors. Moreover, the Executive Department had ‘the same view. Executive Order No: 9801, appearing in the appendix, established the 48-hour. minimum work- week, but it was careful to provide that it should not be “construed as suspending or modifying any provision of the Fair Labor Standards Act”. We . 9 2 7 and 5 of this Order: | 5 2) An departments = agencies of the Federal : Government shall require their contractors to comply with the minimum workweek prescrib- ed in this Order and with policies, directives, and regulations prescribed hereunder, and - . shall promptly take such action as may - re for that purpose. 7 5 f 8 667 3) Nothing in this Order shall 1 L * | uber dine or in conflict with any Federal, | State or law limiting hours of work or with provisions of any ividual or col- lective bargaining with respect to. : rates of pay for hours worked in excess of the 8 agreed or customary workweek, nor shall this ? Order. be construed as suspending or modi- _ fying any provision of the Fair Labor Stand- - ards Act (Act of June 25, 1938; 52 Stat. 1060; 29 U.S.C. 201, et seq.) or any other Federal, State or iocal law re ng to the payment of wages or-overtime.”” ae 8 0 : 7 ‘a 8 oP ae 5 208 (d) of the Act, it is provided; States or any State or political. subdivision of a State, or any labor organization (other than when * N 8 1 . ; k CCC eemiuebauamaitate ose WW 8 44 Sih Semin ste „ impliedly referred to. : : ag 6 . a ‘contract is a disclaimer by. the government that it is the employer. There is nothing in the statute itself else- e "where, to indicate that Congress intended that the words. of the statute ‘excluding the Government should be taken in other than the ordinary meaning. We submit that, according to ordinary understanding, the Government does not stand here us the employer, rather than the respondent. ee , An act of the Government is none the less adminis- trative if in time of peace, instead of war. ‘If the Act is deemed inapplicable because the: procurement ‘of these munitions was an administrative act, it would exclude 5 great segments of the working population because all work -· ers under. government contracts would be excluded. In other, but analogous, situations, exclusion on this argu- ment has been denied. Take the case of the United States mails — as relates to the National Labor Relations Act. employees for contract mail carriers have been held as in commerce. N.L.R.B. v. CARROLL, 120 F. ad 457. As „ Sn AS apart om : mail carriers have adjudged. under the Act. 1 5 THOMPSON. v. DAUGHERTY, 40 F. Supp. 279; FLEM- ING v. GREGORY, * F. — 776; MAGANN v. ‘TRANSPORTA TION 00. 49 F. pine 742. In the case of. WALLING v. PATTON-TULLEY | TRANSPORTA- ION CO., 184 F. ad 945, employees of an independent contractor on dyke and revetment work on the Missouri and Mississippi Rivers were ‘subject to the Fair Labor Standards Act. Insofar as levees and their repairs are _ concerned, that is certainly administrative activity. noe fact, to a limited extent the federal government owns ' these rivers, but not, of course, as fully as it owned the munitions in this case. But counsel, in the court below, urged that general legislation does not- inelude the sover- eign, unless by express words or compelling implication, 3 eiting UNITED STATES v. HOAR, 2:Mason $11, UNIT- ED STATES v. GREEN, 4 Mason 427; UNITED STATES © : v. HUGHES, 26 Fed. Cases 297; and. DOLLAR SAVINGS — „ Bak v. UNITED STATES, 86 U.S. 222. Ovef Ned, however, is the fact that the existence of the government o the’ United States was manifestly considered by the lawmakers and fully provided for to the extent intended by the sole mention of the government in sub-section (d) 15 8 Section e eee : ; . Moreover, the rule of the Hoax, N voHks, “a DOLLAR SAVINGS BANK cases, supra, applies only in 1 5 the situation where the Government is in litigation. In all these cases, the Government was a party. Here the Govern- ment is not a party, and is affected only because, by con- tract, the results of this law-suit may touch the Govern- 4 ment. Rut the fact that the Government may be affected 5 — by this — been held not to — the cost, ph _—_— — 1 a fixed fee ‘contractor 15 ene dee of his contract. | ALABAMA v. KING E BOOZER, CURRY v. UNITED . _ STATES, supra. In those cases, the Court was solieitous to preserve local rules, regulations and laws. Surely Con- ~gress did not intend for a national policy, gmbodied in the 5 Fair Labor Stauthrds Act, to be frustrated in a situation where care is taken to permit the operatign of local policies. This preeise argument was presented and rejected in an | — situation in the Supreme Court of Iowa, in the case of UMTHUM v. DAY & ZIMMERMAN, me. we excerpt trum that ease: “The. statement of J sation Story in the HOAR ‘ae is by no means a hard and fast rule by which the . sovereign e from pusarel terns of » te. ‘tute; purpose, subject. matter, context, tive history and executive interpretation are aids 0 to construction which may indicate. an intent to bring the sovereign within the scope of. the law. UNITED STATES v. COOPER CORPORATION, | 418 U.S. 600, 61 S.Ct. 742, 85 L. Ed. 1071, 1074, ~ 1075, Roberts, J. ‘Cases in which the doctrine of fe the HOAR case have been applied are of two classes: (1) Those where the act, if the ‘sovereign were not exeluded, would deprive it of a recognized or established prerogative title or interest. A elassie example of these cases is, UNITED STATES v. _HOAR itself, holding the sovereign is exempt from 8 general statutes of limitations. (2) Those where ge the act would work obvious absurdity if the public 3 or its officers were not held to be impliedly exclud- ed, as, for example, the application of 7 speed sta- tute to a policeman pursuing a criminal or to a fire i —— 7 8 to a fire alarm. * 5 +) 2 2 L. Ed. $14, $17, 5 a government is resisting UNITED STATES, ‘s08 ‘US. 879, 58 S. Ct. 275, J. Pl of these classes. The to the case. It is not on the contrary the does not fall 4 ation. 20 t of Labor has amicus curiae _ brief urging a reversal. Plainti not an em- payee of the goverament but of f. aa tion. 5 c it it ean be called such, of UNITED STATES v. HOAR. Where a statute is for the public good or to prevent injury and wrong, the sovereign is bound by it although not particularly named therein. NARDONE v. UNITED STATES, supra, 302 U.S. 275, 58 S.Ct. $75, 82 L. Ed. $14, $18; UNITED * | STATES v. HERRON, 20 Wall. 281, 22 L. Ed. 276, 276. It would seem that the Act involved here Was intended for Wer Jory ee, 1 5 ua \ . : ICATION OF EREOR NO. & ‘Munitions Not Cxempt as Goods in the Hands ; of the Ultimate Consumer. 5 Finally, it was held by the cbuirt below that the ~ munitions manufactured here were excluded under the Act, by the provisions of sub-paragraph R . equipment), wares, products, commodities, mer- J27½)000S00 hiatemente character, or any part or ingredient thereof, but does not include goods after their delivery inte me actual physical possession of the ultimate consumer r e manufacturer, or processor thereof.” ws ty atl ih ha lilies peaiians a aug an petitioners labored, did not occur until after these goods - lor at least the raw materials from which the munitions were made) were delivered into the hands of the govern- - ment of the United States, which was the ultimate con- : sumer of the munitions; that the exemptive provision of the above quoted paragraph thus came into operation. ; This view is ‘untenable — firstly, because the ex- i emption does not become effective until after delivery into i the actual physical possession of the ultimate consumer. 25 Here, the actual physical possession on the part of the Gov- ernment did not come about, under any theory, until the goods were processed to completion and were loaded on railroad ears, and, e a 2 red to the arme coe tre on the battle trent. At ay Si j 5 | CNY. 70; 80; ASHLEY CO. „ BRAD- 55 ? — ee hed ie ease 4 (8) for a workweek longer 6 Bx 8 fe — 2 d No employer * *.** e, ‘excess of the hours -* N i HH i 2 BH £33: all ike \a | 5 92 . --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386406_0028%3A03. Public record. Not legal advice.