Angelia Ruffin v. MotorCity Casino, 775 F.3d 807

Plaintiffs are current/former MotorCity Casino security guards in Detroit, assigned to five 8-hour shifts per week.
Guards are required to monitor two-way radios during meal periods and respond to emergencies if called.
A 30-minute meal period is provided by the CBA and paid; guards may not leave casino premises during meals.
Meal periods permit eating, socializing, using phones/Internet, smoking, and other activities, with no compensation for roll-call pre-shift but meals are compensable if predominantly for the employer’s benefit.
Emergency calls may interrupt meals only occasionally; make-up time is available via grievance but no grievances were filed.
District court granted summary judgment holding meal periods non-compensable and allowing offset against roll-call time; plaintiffs appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether meal periods are compensable time under FLSA.	Webb/Kirby/Tibbs contend monitoring radios makes meals primarily for employer profit.	MotorCity argues monitoring is de minimis and meal periods are primarily for employee benefit.	No; meals not compensable; monitoring is de minimis and employees adequately free during meals.
Whether intermittent emergency interruptions during meals render meals compensable.	Interruptions occur and could convert meals to work time.	Interruptions were rare/occasional, not enough to make meals compensable.	No; emergencies rarely/intermittently interrupt meals; not enough to render meals compensable.
Whether being on the premises during meals indicates compensability.	Premises-only meals show employer benefit.	Presence/on-site meals do not necessarily convert to working time; employee can enjoy meals.	No; on-premises requirement does not convert meals to working time given freedom to eat, socialize, and engage in personal activities.

Hill v. United States, 751 F.2d 810 (6th Cir. 1984) (time spent predominantly for employer’s benefit; meal periods non-compensable if employee free to pursue own activities)
Tenn. Coal, Iron & R. Co. v. Muscoda Local No. 123, 321 U.S. 590 (Supreme Court 1944) (work is physical/mental exertion for employer’s benefit; totality of circumstances governs)
F.W. Stock & Sons, Inc. v. Thompson, 194 F.2d 493 (6th Cir. 1952) (time spent predominantly for employer’s benefit during meal periods)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (Supreme Court 1946) (burden on employee to prove compensability; totality of circumstances)
Lamon v. City of Shawnee, 972 F.2d 1145 (10th Cir. 1992) (discusses interruptions and meal-period compensability; not conclusive on radio monitoring)
Reich v. S. New England Telecomm. Corp., 121 F.3d 58 (2d Cir. 1997) (meals spent on premises may be compensable if employer extracts unpaid work)