Integrity Staffing Solutions, Inc. v. Busk

574 U.S. 27, 135 S. Ct. 513, 190 L. Ed. 2d 410 (2014)

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Integrity Staffing Solutions, Inc. v. Busk

United States Supreme Court
574 U.S. 27, 135 S. Ct. 513, 190 L. Ed. 2d 410 (2014)

Facts

Jesse Busk (plaintiff) was a warehouse worker whose job involved retrieving items from warehouse shelves and packaging the items for shipment. Busk’s employer, Integrity Staffing Solutions, Inc. (Integrity) (defendant), required all warehouse workers to undergo antitheft screenings each day before leaving the warehouse. The screenings involved removing wallets, keys, and belts and passing through metal detectors. Busk and another warehouse worker initiated a putative class action, alleging that the Fair Labor Standards Act (FLSA) required their time spent waiting for and undergoing the screenings to be compensated. The workers alleged that the process took an average of 25 minutes per day but could have been reduced to a de minimis amount by adding more screeners or staggering shifts. The district court dismissed the complaint, finding that the screenings fell into a noncompensable category of postliminary activities because they were not an integral and indispensable part of the activities the workers were employed to perform. The United States Court of Appeals for the Ninth Circuit reversed, holding that if the postshift activities were necessary to the principal work performed and done for the employer’s benefit, they were compensable. The United States Supreme Court granted Integrity’s petition for certiorari.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

Concurrence (Sotomayor, J.)

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