## Facts

- A national trade association representing the coin-operated laundry and dry-cleaning industry sought guidance on how the 1966 Fair Labor Standards Act (FLSA) amendments applied to employees of coin-operated laundries.
- The Wage and Hour Administrator responded by letter that coin-operated laundries were subject to the FLSA as amended in 1966.
- The association filed a federal declaratory judgment action seeking to invalidate the Administrator’s letter ruling.
- The district court dismissed for lack of a justiciable case or controversy.
- The association appealed.

## Issues

1. Whether an Administrator’s interpretive letter responding to an industry association’s inquiry created a justiciable case or controversy permitting declaratory relief without awaiting an enforcement action.
2. Whether coin-operated laundries are “establishments engaged in laundering” covered by the FLSA under the 1966 amendments, despite earlier administrative treatment that characterized such businesses as renting machines.

## Decision

- The court of appeals held the dispute was justiciable and the district court had jurisdiction to hear the declaratory judgment action.
- On the merits, the court upheld the Administrator’s coverage position and directed entry of judgment for the Secretary of Labor.
- The court affirmed the outcome (no relief to the association) but rejected the district court’s jurisdictional rationale.

## Legal Principles

- A regulated party may obtain declaratory relief when an agency has taken a sufficiently definite, adverse position with immediate practical consequences, even if no enforcement action has begun.
- In determining coverage under the FLSA amendments, the statutory focus is on whether the establishment is engaged in the covered activity (laundering/cleaning/repairing clothing or fabrics), not on technical characterizations that previously supported exemptions.
- After the 1966 amendments repealed the specific laundry exemption and excluded laundering establishments from the general retail/service exemption, establishments whose business is laundering— including coin-operated laundries—fall within FLSA coverage.

## Conclusion

The D.C. Circuit held that an Administrator’s definitive coverage letter to an industry association presented a justiciable controversy for declaratory judgment review and concluded that coin-operated laundries are covered “laundering” establishments under the FLSA as amended in 1966, warranting judgment for the Secretary on the merits.


Nat'l Automatic Laundry & Cleaning Council v. Shultz, 443 F.2d 689 (D.C. Cir. 1971)