The ruling underscores an important limit on the FLSA: working overtime does not necessarily create a federal claim for every unpaid hour in that week.
For employers that already pay nonexempt employees for all hours worked, the compliance impact may be limited. Even so, the decision could still matter in wage-and-hour litigation by narrowing available FLSA remedies, especially in collective actions.
Because the Fourth Circuit has taken a different view, the issue may draw further appellate scrutiny, including possible Supreme Court review. In jurisdictions that follow the Third Circuit’s approach, plaintiffs may increasingly add state wage payment claims.