In Christensen v. Harris County, 529 U.S. 576, 120 S.Ct. 1655, 146 L.Ed.2d 621 (2000), the Supreme Court determined that the Fair Labor Standards Act (FLSA) limits the State "from compelling employees to utilize accrued compensatory time." 120 S.Ct. at 1660. In that case, Harris County, Texas gave employees statutorily required accrued compensatory time as payment for overtime above the statutory maximum of 40 hours per week. The County found that employees were accruing more compensatory time than it was going to be able to afford to pay out. Upon request by the County, the Department of Labor issued an opinion letter authorizing it to require non-exempt employees to use or take compensatory time. In response, the County instituted a policy setting a maximum number of compensatory hours that may be accumulated and if the employee does not take steps to reduce accumulated compensatory time, the County may order the employee to use his compensatory time at specific times. Although the employees conceded that "nothing in the Fair Labor Standards Act ("FLSA") expressly prohibits" Harris County's policy, they complained that according to the canon of expressio unius est exclusio alterius, the "express grant of control to employees to use the compensatory time, subject to the limitation regarding undue disruptions of workplace operations, implies that all other methods of spending compensatory time are precluded." Id. at 1660. The Supreme Court found this argument unpersuasive explaining that the fact that the statute provides a "minimal guarantee that an employee will be able to make some use of compensatory time when he requests to use it," does not mean that the statute does not set forth "the exclusive method by which compensatory time can be used, but sets up a safeguard to ensure that an employee will receive timely compensation for working overtime." Id. at 1661. Although the Supreme Court acknowledged that "when a statute limits a thing to be done in a particular mode, it includes a negative of any other mode," Id. at 1660, "the thing to be done" in the disputed statute is the minimum guarantee. Id. at 1661. In Christensen v. Harris County, 529 U.S. 576, 587, 120 S.Ct. 1655, 146 L.Ed.2d 621 (2000), the Supreme Court "confronted an interpretation contained in an opinion letter, not one arrived at after, for example, a formal adjudication or notice-and-comment rulemaking." 529 U.S. at 587, 120 S.Ct. 1655. The Court concluded that: Interpretations contained in policy statements, agency manuals, and enforcement guidelines, all of which lack the force of law - do not warrant Chevron-style deference. Instead, interpretations contained in formats such as opinion letters are "entitled to respect" under our decision in Skidmore v. Swift & Co., 323 U.S. 134, 65 S.Ct. 161, 89 L.Ed. 124 (1944), but only to the extent that those interpretations have the "power to persuade." Id.