Integrity Staffing Sols., Inc. v. Busk - 574 U.S. 27, 135 S. Ct. 513 (2014)

Rule:

An activity is integral and indispensable to the principal activities that an employee is employed to perform—and thus compensable under the Fair Labor Standards Act of 1938, 29 U.S.C.S. § 201 et seq.—if it is an intrinsic element of those activities and one with which the employee cannot dispense if he is to perform his principal activities.

Facts:

Petitioner Integrity Staffing Solutions, Inc., required its hourly warehouse workers, who retrieved products from warehouse shelves and packaged them for delivery to Amazon.com customers, to undergo a security screening before leaving the warehouse each day. Respondents, former employees, sued the company alleging that they were entitled to compensation under the Fair Labor Standards Act of 1938 (FLSA) for the roughly 25 minutes each day that they spent waiting to undergo and while undergoing those screenings. They also alleged that the company could have reduced that time to a de minimis amount by adding screeners or staggering shift terminations and that the screenings were conducted to prevent employee theft and, thus, for the sole benefit of the employers and their customers. The District Court dismissed the complaint for failure to state a claim, holding that the screenings were not integral and indispensable to the employees' principal activities but were instead postliminary and noncompensable. The U.S. Court of Appeals for the Ninth Circuit reversed in relevant part, asserting that postshift activities that would ordinarily be classified as noncompensable postliminary activities were compensable as integral and indispensable to an employee's principal activities if the postshift activities were necessary to the principal work and performed for the employer's benefit.

Issue:

Were the respondents entitled to compensation under the FLSA for the 25 minutes they spent waiting to undergo security screenings?

Answer:

No.

Conclusion:

The Supreme Court noted that an activity was integral and indispensable to the principal activities that an employee is employed to perform, and thus compensable under the FLSA, if it was an intrinsic element of those activities and one with which the employee cannot dispense if he was to perform his principal activities. In the case at bar, the Court held that the security screenings were noncompensable postliminary activities because the employer did not employ its workers to undergo security screenings, and the screenings were not an intrinsic element of retrieving products from warehouse shelves or packaging them for shipment.