Sandifer v. United States Steel Corp.

Background

A group of current and former steelworkers sued their employer for pay for time spent putting on and taking off required protective gear. They listed twelve common items — jacket, pants, hood, hardhat, snood, wristlets, gloves, leggings, boots, safety glasses, earplugs, and a respirator — and sought backpay for that donning-and-doffing time. The District Court and the Court of Appeals concluded much of that time was covered by a clause in the union contract or was so small as to be disregarded, and the employer argued the disputed time fit a statutory exception.

Reasoning

The Court examined the phrase "changing clothes" in the wage law and gave "clothes" its ordinary meaning: items designed and used to cover the body and commonly regarded as dress. The Court held that protective clothing that covers the body fits that meaning and that "changing" can include altering or layering, not only complete substitution. Applying those rules, the Court concluded most of the donning and doffing at issue qualifies as "changing clothes" under the statute, while safety glasses, earplugs, and respirators do not. The Court also rejected a broad minute-by-minute exemption and instead said courts should treat a period as clothes-changing when the vast majority of the time is devoted to putting on and taking off clothes.

Real world impact

The ruling means employers and unions may lawfully bargain to make most donning-and-doffing time nonpayable under the contract exception. The decision affects steelworkers and similar factory employees who use protective clothing and reduces the need for judges to parse tiny time segments. The Court affirmed the lower courts’ judgment.