Anderson v. Mt. Clemens Pottery Co.
Headline: Ruling forces employers to count on-premises walking and required pre-work tasks as paid work, eases employees’ proof burden for unpaid overtime, and sends the case back to calculate what is owed.
Holding: The Court held that walking on the employer’s premises after clocking in and necessary pre-work activities must be counted as compensable working time, employees may prove unpaid work by reasonable inference, and the case was remanded.
- Requires employers to count certain walking and prep time as paid work.
- Lowers burden on employees to prove unpaid overtime when employer records are inadequate.
- Remands case to calculate damages based on reasonable inference.
Summary
Background
A pottery company in Michigan ran a large plant where about 1,200 people worked, most paid by piece rate. Workers used time clocks and were given a 14-minute period to punch in, walk to work stations across long distances, and do short preparatory tasks like putting on aprons and readying equipment. Seven employees and their union sued, saying the company’s method of rounding clock times undercounted actual work and deprived them of overtime pay. A trial master and the Court of Appeals largely found for the company; a trial court had used a formula to add a few minutes for many employees and awarded back pay.
Reasoning
The Court addressed two main questions: what parts of the pre-shift period count as work, and how employees may prove unpaid work when employer records are incomplete. The Court agreed that actual production began and ended at scheduled times, but it held that time spent walking on the employer’s premises from the time clock to the workstation, and necessary preparatory tasks at the workstation, are work when they are required by the employer. The Court also rejected an impossibly strict proof rule for workers: if employer records are inadequate, an employee who shows he performed unpaid work can rely on reasonable inferences about the amount of time, after which the employer must produce evidence to show the precise amount or refute that inference.
Real world impact
The Court reversed the appeals court and sent the case back for a factual determination of how much walking and preparatory time was actually required and for a calculation of back pay, allowing small approximations when exact minutes cannot be shown. The Court also said very small, trivial amounts can be ignored under a de minimis rule.
Dissents or concurrances
A dissent argued the Court was wrong to require employers to record and pay these small pre-work minutes, warning that measuring and paying such brief tasks is impractical and often already reflected in job pay rates.
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