In Arnold v. Ben Kanowsky, Inc., 361 U.S. 388, 392, 80 S.Ct. 453, 4 L.Ed.2d 393 (1960), the Court applied its canon of strict construction against employers in the course of interpreting ambiguous statutory language in the former exemption from Fair Labor Standards Act ("FLSA") overtime requirements for a retail establishment. See 29 U.S.C. 213(a)(2), (4) (1949). Because there was no regulatory interpretation of the relevant provisions of 213, the Court needed to consider legislative history, past precedent, and canons of construction to reach its result. See Arnold, 361 U.S. at 392-94, 80 S.Ct. 453.