A U.S. Supreme Court ruling has prompted a federal appeals court to recognize that a verbal complaint made to an employer can precede the filing of a retaliation claim under the Fair Labor Standards Act.

The U.S. Court of Appeals for the Second Circuit abandoned an interpretation of the law that held a plaintiff must file a written complaint with the government—not with their employer—to bring an action under the act, 29 U.S.C. §§215(a)(3).