McLaughlin v. Richland Shoe Co.

486 U. S. 128

May 16, 1988

A labor law had a statute of limitations of 2 years in most cases, but 3 years in cases of “willful” violations. A labor dispute at a shoe company ended up turning on which limitation applied. Many lower courts had held that a violation was “willful” if the employee knew that that labor law was “in the picture.” The shoe company charged that this definition was way overbroad.

In a 6-3 ruling, the Court agreed. Stevens said that the “in the picture” standard could probably make almost any violation “willful.” In a recent case about a different law, “willful” had been defined as knowing that your conduct is illegal, or showing reckless disregard for that possibility. That, Stevens said, was an appropriate definition. He dismissed an alternative definition which would make “willful” any action taken despite knowledge of an appreciable possibility of illegality. That definition, said Stevens, could render a violation based on a good faith misinterpretation “willful.”

Marshall, joined by Brennan and Blackmun, thought the ‘appreciable possibility’ definition was totally appropriate. The definition that the majority adopted might have worked fine for the law it was originally crafted for, but textual differences between that law and the labor law at issue counseled against adopting the same definition so readily. Sorry Marshall, but I’m not convinced. The majority’s narrow definition is good, and I’m glad it was adopted.

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