CARIENE CADENA V. CUSTOMER CONNEXX LLC, 51 F.4th 831

Background

Plaintiffs are hourly call-center employees at Connexx who use employer‑provided desktop computers and a "soft phone" (Five9) to receive customer calls and schedule pickups.
Employees must boot or wake the workstation, log in, and then open an electronic timekeeping program to clock in; boot times ranged from ~1–20 minutes (plaintiffs estimated averages of 6.8–12.1 minutes).
At shift end employees close programs, clock out, and log off or shut down; shutdown time estimates averaged ~4.75–7.75 minutes and parties dispute whether shutdown was required.
Plaintiffs sued under the FLSA claiming unpaid time booting up and shutting down computers; district court granted summary judgment for employer, treating boot/shutdown and clocking as non‑compensable preliminary/postliminary tasks.
The Ninth Circuit reversed as to booting: it held booting is "integral and indispensable" because a functional computer is necessary to perform the employees’ principal duties, and remanded for further factual determinations about shutdown time, de minimis, and employer knowledge.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether time spent booting/waking employer computers before clocking in is compensable under the FLSA	Booting is integral and indispensable because a functional computer (soft phone, scripts, customer data) is required to perform principal duties	Booting is a preliminary task like waiting to clock in and not a principal activity; employees could perform work without the electronic timekeeping system	Booting/waking is a principal activity and compensable because employees cannot perform core duties without a working computer; reversed summary judgment for employer
Whether time spent shutting down computers after clocking out is compensable	Shutdown time is compensable if it is required and integral to duties	Shutdown is postliminary and not integral; employer disputes any instruction to fully shut down	Left to district court on remand to resolve factual disputes and whether shutdown is compensable
Whether the de minimis doctrine bars recovery for boot time	Boot time is regular and administratively recordable, so not de minimis	Boot time is insubstantial and therefore noncompensable	Court did not decide; remanded for district court factfinding on de minimis applicability
Whether employer had actual/constructive knowledge of uncompensated time (affecting liability)	Employer knew or had reason to know because the practice was required and regular	Employer had a reporting procedure (punch claim) and lacked knowledge, so not liable for unreported time	Court did not decide; remanded for factual determination by district court

Key Cases Cited

Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946) (early broad view of compensable work time on employer premises)
Steiner v. Mitchell, 350 U.S. 247 (1956) (activities integral and indispensable to principal activities are compensable)
Mitchell v. King Packing Co., 350 U.S. 260 (1956) (pre‑shift equipment preparation can be compensable)
Tennessee Coal, Iron & R.R. Co. v. Muscoda Local No. 123, 321 U.S. 590 (1944) (definition of "work" as exertion pursued for employer's benefit)
IBP, Inc. v. Alvarez, 546 U.S. 21 (2005) (integral and indispensable activities treated as principal activities; continuous workday analysis)
Integrity Staffing Sols., Inc. v. Busk, 574 U.S. 27 (2014) (not all employer‑required activities are integral and indispensable)
Sandifer v. U.S. Steel Corp., 571 U.S. 220 (2014) (discussion of limits on de minimis doctrine in FLSA context)
Lindow v. United States, 738 F.2d 1057 (9th Cir. 1984) (recognizing de minimis doctrine in FLSA context)
Peterson v. Nelnet Diversified Solutions, LLC, 15 F.4th 1033 (10th Cir. 2021) (similar call‑center boot‑time claim; held booting compensable and not de minimis)
Forrester v. Roth's I.G.A. Foodliner, Inc., 646 F.2d 413 (9th Cir. 1981) (employer liability depends on knowledge of employee's overtime)