Pittard v. Red River Oilfield Services, LLC, 4:15-cv-03753

Background

Pittard worked as an electromagnetic inspection (EMI) helper for Red River from Sept. 2014–Dec. 2015 and resigned alleging pay was short for hours worked under the FLSA.
He often traveled from his South Texas home to jobs in West Texas/New Mexico, sometimes riding in a company truck driven by a lead inspector and sometimes driving his own car.
On workdays the crew sometimes met at the company shop where Pittard helped pick up supplies and hook up trailers before driving to the jobsite.
Pittard claims his timesheets/paystubs omitted compensable hours (including drive time from the shop to jobsites) and that time was ‘‘shaved off’’ paystubs.
Red River produced timesheets, daily reports, and missing paystubs showing payments for disputed hours and explained typographical/time-reporting errors.
The court considered whether travel and shop activities were "integral and indispensable" to principal activities and whether Pittard presented sufficient evidence to calculate unpaid hours.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are travel hours between home and remote worksites compensable under the Portal‑to‑Portal Act?	Pittard contends travel to distant jobs (often in company truck) should be paid because it benefits employer.	Travel from home to work is noncompensable; Pittard chose where to live and whether to ride in company vehicle.	Not compensable — home-to-work/long commute travel not "integral and indispensable."
Are activities at the company shop (loading supplies, hooking trailers) and subsequent shop→jobsite drive time compensable?	Pittard argues those hours were not reflected on timesheets and should be paid.	Red River contends records captured work time and paid employees; some reported discrepancies were typos or resolved by additional paystubs.	Compensable — shop activities and drive from shop to jobsite are integral and indispensable, but entitlement alone does not decide liability without provable hours.
Did Pittard present sufficient evidence to prove amount of uncompensated work?	Pittard offered handwritten notes and deposition estimates of 8–10 unpaid drive hours/week and pointed to specific paystub discrepancies.	Defendant showed corrected daily reports/timesheets and produced missing paystubs; argued Pittard’s notes conflate compensable and noncompensable time and are speculative.	Insufficient evidence — notes and estimates are speculative, sporadic, and fail to separate noncompensable travel; summary judgment for defendant.
Are alleged payroll ‘‘shaving’’/specific paystub underpayments supported by the record?	Pittard highlighted specific paystubs/timesheets claiming missing hours.	Defendant produced corrected records and the missing paystub showing those hours were paid; identified typographical errors in timesheets.	Not supported — alleged underpayments explained by record corrections; no genuine dispute.

Key Cases Cited

Bridges v. Empire Scaffold, L.L.C., 875 F.3d 222 (5th Cir.) (defining and applying "integral and indispensable" after Busk)
Integrity Staffing Sols., Inc. v. Busk, 135 S. Ct. 513 (2014) (Supreme Court rule that only activities integral and indispensable to principal activities are compensable under Portal‑to‑Portal)
Vega v. Gasper, 36 F.3d 417 (5th Cir.) (commute and optional employer transportation not compensable where employees not required to ride and performed no work en route)
Harvill v. Westward Comm’cns, L.L.C., 433 F.3d 428 (5th Cir.) (plaintiff must present evidence to show amount and extent of uncompensated work)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946) (plaintiff must show by just and reasonable inference the amount of uncompensated work)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard where nonmoving party bears burden)