Integrity Staffing Solutions, Inc. v. Busk
Headline: Court rules that mandatory end-of-day security screenings for warehouse workers are not compensable under federal wage law, reversing the appeals court and allowing employers to avoid paying workers for screening wait time.
Holding:
- Makes end-of-shift security screening wait time unpaid for warehouse workers under the FLSA.
- Limits wage claims for employer-required postshift screenings and similar exit checks.
- Says bargaining, not court wage law, is the avenue to shorten screening wait times.
Summary
Background
An employer that staffs Amazon warehouses required hourly warehouse workers to submit to security screenings before leaving at the end of each day. Two employees from Nevada said the screenings and the wait to be screened took roughly 25 minutes daily and sued under the federal wage law seeking pay for that time. A district court dismissed the claim, but the Court of Appeals said the screenings were necessary to the workers’ jobs and should be paid, prompting review by the Supreme Court.
Reasoning
The central question was whether time spent waiting for and undergoing employer-required security checks counts as compensable work under the Fair Labor Standards Act and the Portal-to-Portal Act. The Court explained that only activities that are an intrinsic, indispensable part of the job are compensable. It contrasted examples like required protective clothing or knife sharpening (compensable) with activities that merely occur before or after the workday. Because retrieving and packing products were the employees’ principal duties and the screenings were not intrinsic to performing those duties, the Court held the screening time was not compensable. The Court also said an employer’s choice to require an activity, or the possibility of shortening wait time, does not make it compensable.
Real world impact
The decision means workers required to undergo similar postshift security checks will generally not get additional pay for the waiting and screening time under the federal wage law. The ruling reverses the appeals court in this case and leaves arguments about shortening wait time to bargaining or workplace arrangements rather than wage litigation.
Dissents or concurrances
Justice Sotomayor, joined by Justice Kagan, agreed with the judgment but wrote to clarify that “indispensable” means an activity cannot be skipped without harming the safety or effectiveness of the principal work performed.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?