IBP, Inc. v. Alvarez
The Court ruled that once workers begin putting on required protective safety gear, the time they then spend walking to their workstations counts as paid work under federal wage law, because the workday has already begun.
But the Court also held that time spent merely waiting to get that gear before putting it on is not automatically paid time, drawing a line between waiting-to-don and the donning itself, and sending one of the two cases back for further proceedings under that distinction.
How it got here: The Ninth Circuit ruled for the Washington workers on walking time; the First Circuit ruled against the Maine workers on both walking and waiting time; the Supreme Court took both cases to resolve the conflict.
The Case in Depth
What happened
Employees at a beef and pork plant in Washington and a poultry plant in Maine were required to put on protective clothing and equipment — hardhats, aprons, gloves, and specialized gear like chain-link aprons and arm guards — before doing their jobs. Workers in both plants sued their employers, arguing they were owed pay under federal wage law for time spent putting on and taking off this gear, walking between locker rooms and production floors, and waiting to receive equipment.
The question before the Court
Must meat and poultry plant workers be paid for time spent walking to and from where they put on required safety gear, and for time spent waiting to put that gear on?
Why it matters
Meatpacking, poultry-processing, and other manufacturing workers nationwide who must don specialized safety gear will be paid for the minutes they spend walking to and from their stations afterward, but not for time spent standing around waiting to receive that gear. Employers in gear-intensive industries must recalibrate payroll practices and time-tracking systems to match this line.
What changes now
The Ninth Circuit's ruling in favor of the Washington meatpacking workers is affirmed and final. The First Circuit's ruling against the Maine poultry workers is affirmed in part (predonning waiting time remains unpaid) and reversed in part (postdonning walking time and predoffing waiting time must be paid), and that case is sent back to the lower courts for further proceedings consistent with this distinction.
What this does not decide
The Court did not decide whether donning and doffing of ordinary, non-unique gear like hardhats or hairnets is compensable, nor did it revisit whether such time is too minimal ('de minimis') to count; those factual determinations were left undisturbed or for remand.
How the Court got there
The legal reasoning, step by step
- The Court relied on its earlier ruling in Steiner v. Mitchell, which held that any activity 'integral and indispensable' to a worker's main job duties counts as a 'principal activity' under the Portal-to-Portal Act, the 1947 law that excludes purely preliminary or trailing tasks from paid time.
- Because the statute uses the identical phrase 'principal activity or activities' in both the section addressing what starts the workday and the section addressing what is excluded as preliminary or postliminary, the Court held the phrase must mean the same thing in both places — so integral gear-donning both triggers and counts within the paid workday.
- Applying the 'continuous workday rule' — the settled principle that everything between an employee's first and last principal activity of the day is part of the paid workday — the Court concluded that walking from the locker room to the production floor after donning gear happens inside that continuous workday, not before or after it.
- The Court distinguished this case from its earlier decision in Anderson v. Mt. Clemens Pottery Co., where workers walked to their stations before any work-related activity had begun; here, the walking followed the start of a principal activity (donning), so it fell inside the workday rather than in the excluded preliminary period.
- Turning to time spent merely waiting to receive gear before putting it on, the Court found that such waiting is not itself 'integral and indispensable' to the job in the same direct way that donning is, because whether waiting is needed varies by circumstance rather than being inherent to the job.
- The Court therefore held that predonning waiting time remains an excluded 'preliminary' activity that does not start the paid workday, while waiting to take gear off at the end of a shift is compensable because it happens after the workday has already begun through the initial principal activity.
Doctrinal impact
Cases affected by this decision
Reaffirms Steiner v. Mitchell (350 U.S. 247)
The Court relies on Steiner's rule that gear integral to a job counts as a compensable principal activity.
Distinguishes Anderson v. Mt. Clemens Pottery Co. (328 U.S. 680)
The Court says the pre-workday walking in Anderson differs from walking that occurs after work has begun.