In an article on the Supreme Court's decision in Christopher v SmithKline, Littler’s Lee Schreter commented that the ruling "has narrowed the circumstances under which courts will defer to agency interpretations of their own ambiguous regulations.” Contrary to the Department of Labor’s interpretation, the high court determined that biopharma sales representatives are "outside salesmen" and therefore do not meet the requirements under the Fair Labor Standards Act for minimum wage and maximum hours for overtime pay.

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