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contractappealrespondent

contractappeal

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Foley Bros. v. Filardo, 336 U.S. 281, 69 S.Ct. 575, 93 L.Ed. 680

Facts

In 1941, petitioners contracted with the United States to build public works in Iraq and Iran. The contract did not specifically include provisions of the Eight Hour Law, which limits work hours for laborers and mechanics. In 1942, the respondent, an American citizen, was hired as a cook and frequently worked more than eight hours a day. After being denied overtime pay for his extra hours, he sued the petitioners, leading to a series of court decisions culminating in the New York Court of Appeals ruling that the Eight Hour Law applied to the contract.

In 1941 petitioners contracted on a cost-plus basis to build certain public works on behalf of the United States in the East and Near East, particularly in Iraq and Iran.

Issue

Does the Federal Eight Hour Law apply to contracts between the United States and private contractors for construction work performed in foreign countries?

The question is rather whether Congress intended to make the law applicable to such work.

Rule

The Eight Hour Law mandates that every contract involving the United States must include a provision limiting laborers and mechanics to eight hours of work per day, with penalties for violations. However, the applicability of this law to work performed outside U.S. territory is in question.

This Act provides that ‘Every contract made to which the United States * * * is a party * * * shall contain a provision that no laborer or mechanic doing any part of the work contemplated by the contract, in the employ of the contractor or any subcontractor * * * shall be required or permitted to work more than eight hours in any one calendar day upon such work; * * *.’

Analysis

The Supreme Court analyzed the statutory language and legislative history of the Eight Hour Law, concluding that there was no clear congressional intent to apply the law to contracts executed in foreign countries. The Court emphasized that the law was designed to address domestic labor conditions and that extending its reach to foreign work would impose U.S. labor standards on foreign nations, which was not intended by Congress.

We find nothing in the Act itself, as amended, nor in the legislative history, which would lead to the belief that Congress entertained any intention other than the normal one in this case.

Conclusion

The Supreme Court reversed the New York Court of Appeals' decision, ruling that the Eight Hour Law does not apply to contracts for work performed in foreign countries.

Since we decide that the Eight Hour Law is inapplicable to a contract for the construction of public works in a foreign country over which the United States has no direct legislative control, it is unnecessary to decide whether the law, either directly or via the third party beneficiary contract route, gives an employee who is covered by it a cause of action against his employer for overtime wages.

Who won?

Foley Bros., Inc. prevailed in the case because the Supreme Court determined that the Eight Hour Law did not extend to contracts executed in foreign countries, thus denying the employee's claim for overtime pay.

Judgment of Court of Appeals of New York reversed.

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