Cariene Cadena v. Customer Connexx LLC, 107 F.4th 902

Call center workers at Customer Connexx LLC claimed they were not paid overtime for time spent booting up and shutting down computers needed to clock in and out each shift.
Employees had to be ready to take calls at their scheduled start time and could not clock in more than 7 minutes prior to that time; workstations were not permanently assigned, and computer speeds varied.
The company computed work time to the nearest quarter hour and used a computer-based timekeeping system, with a manual adjustment policy for certain clock-in delays.
Plaintiffs brought a collective action under the Fair Labor Standards Act (FLSA), seeking compensation for alleged uncompensated pre- and post-shift work.
The district court twice granted summary judgment for Connexx, finding any uncompensated time was de minimis and/or could have been adjusted through the timekeeping system.
On appeal, the Ninth Circuit reversed and remanded, holding disputed issues of material fact remain regarding whether the time was de minimis and whether Connexx's policies effectively prevented compensation for the work.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the de minimis doctrine apply to FLSA overtime claims?	Sandifer abrogated de minimis doctrine for FLSA wage claims.	Sandifer is limited to § 203(o); de minimis applies under § 207.	De minimis doctrine still applies in these circumstances.
Was the time spent booting up/down de minimis?	Time was regular, could be substantial, and easily tracked.	Time was minimal, irregular, and impractical to record.	Genuine factual dispute; summary judgment improper.
Did Connexx have actual/constructive knowledge of the work?	Connexx knew pre-shift work was required for call readiness.	Connexx provided a procedure for workers to claim extra time.	Factual dispute over whether Connexx prevented payment.
Did Connexx’s policies compensate for this work?	Punch claim process did not permit pay for pre-shift time.	Employees could and did adjust time for delays.	Factual dispute; summary judgment improper.

Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (establishes that only substantial off-the-clock work is compensable under the FLSA)
Lindow v. United States, 738 F.2d 1057 (sets three-factor test for application of de minimis doctrine under the FLSA)
Corbin v. Time Warner Ent.-Advance/Newhouse P’ship, 821 F.3d 1069 (applies de minimis doctrine to minor pre-shift work in call center context)
Rutti v. Lojack Corp., 596 F.3d 1046 (holds regular, required off-the-clock work may preclude de minimis finding)
Marsh v. J. Alexander’s LLC, 905 F.3d 610 (recognizes de minimis exception for minor FLSA wage claims)
Sandifer v. U.S. Steel Corp., 571 U.S. 220 (limits de minimis doctrine for time spent changing clothes under § 203(o) of the FLSA)