The dispute centered on Americare Healthcare Services, an Ohio-based home care provider that exclusively employs live-in workers to serve elderly or disabled clients through state Medicaid waiver programs. Between 95-99.9% of Americare's workers provide care to their own family members based on the cultural and religious beliefs of the Nepali Ohioan community the company serves. The Department of Labor sued the company and its owner Dilli Adhikari for failing to pay overtime wages between October 2018 and October 2021.
Judge Jane Stranch, writing for the majority, found the 2013 regulation was a valid exercise of the Secretary of Labor's expressly delegated authority under the Fair Labor Standards Act. "The statutory language refers broadly to 'domestic service employment' and to 'companionship services.' It expressly instructs the agency to work out the details of those broad definitions," Stranch wrote, citing the Supreme Court's 2007 decision in Long Island Care at Home v. Coke. The court applied the three-step framework from Loper Bright Enterprises v. Raimondo, determining the delegation was constitutional, within proper boundaries, and reasonably explained.
The case arose after the district court granted summary judgment to the Department, holding that Americare violated FLSA overtime requirements and that the 2013 third-party regulation was valid. The Department had changed course from its 1975 approach citing "dramatic changes" in the home care industry, where professional home care replaced nursing home care as the primary option for seniors needing assistance.
The decision affirms federal oversight of a growing home care industry increasingly relied upon by aging Americans. The ruling also reinforced that post-Loper Bright, agencies retain significant regulatory authority when Congress provides express delegation language, as distinguished from the implied delegations that Chevron previously protected.