Supreme Court issues ruling in FLSA arena

Petitioner Kasten brought an antiretaliation suit against his formeremployer, respondent (Saint-Gobain), under the Fair Labor Stan-dards Act of 1938 (Act), which provides minimum wage, maximum hour, and overtime pay rules; and which forbids employers “to dis-charge . . . any employee because such employee has filed any com-plaint” alleging a violation of the Act, 29 U. S. C. §215(a)(3). In a re-lated suit, the District Court found that Saint-Gobain violated the Act by placing timeclocks in a location that prevented workers from receiving credit for the time they spent donning and doffing work-related protective gear. In this suit Kasten claims that he was dis-charged because he orally complained to company officials about thetimeclocks. The District Court granted Saint-Gobain summaryjudgment, concluding that the Act’s antiretaliation provision did notcover oral complaints. The Seventh Circuit affirmed.
Held: The scope of statutory term “filed any complaint” includes oral, aswell as written, complaints. Pp. 4–15.
(a) The interpretation of the statutory phrase “depends upon read-ing the whole statutory text, considering the [statute’s] purpose andcontext . . . , and consulting any precedents or authorities that informthe analysis.” Dolan v. Postal Service, 546 U. S. 481, 486. The text, taken alone, cannot provide a conclusive answer here. Some diction-ary definitions of “filed” contemplate a writing while others permitusing “file” in conjunction with oral material. In addition to diction-ary definitions, state statutes and federal regulations sometimes con-template oral filings, and contemporaneous judicial usage shows thatoral filings were a known phenomenon at the time of the Act’s pas-sage. Even if “filed,” considered alone, might suggest a narrow interpretation limited to writings, “any complaint” suggests a broad inter-pretation that would include an oral complaint. Thus, the three-word phrase, taken by itself, cannot answer the interpretive question. The Act’s other references to “filed” also do not resolve the linguistic ques-tion. Some of those provisions involve filed material that is virtually always in writing; others specifically require a writing, and the re-mainder, like the provision here, leave the oral/written question un-resolved. Since “filed any complaint” lends itself linguistically to thebroader, “oral” interpretation, the use of broader language in other statutes’ antiretaliation provisions does not indicate whether Con-gress did or did not intend to leave oral grievances unprotected here.Because the text, taken alone, might, or might not, encompass oralcomplaints, the Court must look further. Pp. 4–8.
Several functional considerations indicate that Congress in-tended the antiretaliation provision to cover oral, as well as written, complaints. Pp. 8–14.
A narrow interpretation would undermine the Act’s basic ob-jective, which is to prohibit “labor conditions detrimental to themaintenance of the minimum standard of living necessary for health,efficiency, and general well-being of workers,” 29 U. S. C. §202(a).The Act relies for enforcement of its substantive standards on “infor-mation and complaints received from employees,” Mitchell v. Robert DeMario Jewelry, Inc., 361 U. S. 288, 292, and its antiretaliation pro-vision makes the enforcement scheme effective by preventing “fear ofeconomic retaliation” from inducing workers “quietly to accept sub-standard conditions,” ibid. Why would Congress want to limit the en-forcement scheme’s effectiveness by inhibiting use of the Act’s com-plaint procedure by those who would find it difficult to reduce theircomplaints to writing, particularly the illiterate, less educated, oroverworked workers who were most in need of the Act’s help at thetime of passage? Limiting the provision’s scope to written complaintscould prevent Government agencies from using hotlines, interviews, and other oral methods to receive complaints. And insofar as the provision covers complaints made to employers, a limiting reading would discourage using informal workplace grievance procedures tosecure compliance with the Act. The National Labor Relations Act’s antiretaliation provision has been broadly interpreted as protecting workers who simply “participate[d] in a [National Labor Relations]Board investigation.” NLRB v. Scrivener, 405 U. S. 117, 123. The similar enforcement needs of this related statute argue for a broad interpretation of “complaint.” The Act’s requirement that an em-ployer receive fair notice of an employee’s complaint can be met byoral, as well as written, complaints. Pp. 8–12.
(2) Given the delegation of enforcement powers to federal administrative agencies, their views about the meaning of the phrase should be given a degree of weight. The Secretary of Labor has con-sistently held the view that “filed any complaint” covers both oral and written complaints. The Equal Employment Opportunity Commis-sion has set out a similar view in its Compliance Manual and in mul-tiple briefs. These views are reasonable and consistent with the Act. And the length of time they have been held suggests that they reflect careful consideration, not “post hoc rationalizatio[n].” Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co., 463 U. S. 29, 50. Pp. 12–13.
After engaging in traditional statutory interpretation meth-ods, the statute does not remain sufficiently ambiguous to warrantapplication of the rule of lenity. Pp. 13–14.
This Court will not consider Saint-Gobain’s alternative claimthat the antiretaliation provision applies only to complaints filedwith the Government, since that claim was not raised in the certio-rari briefs and since its resolution is not a “ ‘predicate to an intelli-gent resolution’ ” of the oral/written question at issue, Caterpillar Inc. v. Lewis, 519 U. S. 61, 75, n. 13. Pp. 14–15.
570 F. 3d 834, vacated and remanded.

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