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Supreme Court denies wage claims by Amazon.com warehouse workers

The United States Supreme Court denies wage claims by Amazon.com warehouse workers. 

In a unanimous decision, the United States Supreme Court held that warehouse workers who packaged deliveries for Amazon.com customers, were not entitled to compensation under the Fair Labor Standards Act of 1938 (FLSA) for time spent undergo­ing security screenings before leaving the warehouse each day. 

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. Several former employees sued Integrity Staffing Solutions, Inc. alleging they were entitled to compensation under the Fair Labor Standards Act for the time they spent each day waiting to undergo and undergoing those screenings. The former employees further alleged that the screenings were for the sole benefit of the employers and their customers, rather than the employees, as they were intended to prevent employee theft.

Applying the Portal-to-Portal Act, which exempts employers from liability for certain work-related activities, including preliminary or postliminary activities, “which occur either prior to the time on any particular workday at which such employee commences, or subsequent to the time on any particular workday at which he ceases, such principal activity or activities” (29 U. S. C. §254(a)), the Court held the security screenings at issue in the case were not compensable postliminary activities, since they were not integral and indispensable to the employee’s job duties.

The Court explained that “an activity is integral and indispensable to the principal activities that an employee is employed to perform—and thus compensable under the FLSA—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.”

Relative to the security screenings at issue in the case, the Court determined they were not the “principal activity or activities which [the] employee is employed to perform,” as “Integrity Staffing did not employ its workers to undergo security screenings, but to retrieve products from warehouse shelves and package those products for shipment to Amazon customers.”  Indeed, “Integrity Staffing could have eliminated the screenings altogether without impairing the employees’ ability to complete their work.”

Since the Court concluded the employees’ time spent waiting to undergo and undergoing Integrity Staffing’s security screenings is not “an activity is integral and indispensable to the principal activities that an employee is employed to perform,” the Supreme Court denied the employees’ claims for compensation for such time under the Fair Labor Standards Act.

Resources

Integrity Staffing Solutions, Inc. v. Busk 574 U.S. ___ (2014)

Fair Labor Standards Act of 1938

Los Angeles Employment Lawyers