Robert Bartlett v. City of Chicago, 992 F.3d 607

Current and former Chicago Police SWAT operators sued the City under the FLSA, IMWL, and IWPCA seeking pay for time spent transporting, loading/unloading, and securing SWAT weapons and gear at their homes (and related commute time).
SWAT operators carry specialized weapons/gear, use a squad rotation, and may be called off-duty to respond to critical incidents; CPD issued take-home vehicles and issued policies forbidding leaving rifles in vehicles and directing secure storage (often in residences).
CPD policy history: earlier storage at Homan Square/weapons truck; 2009 Special Order authorized take-home rifles and barred storing rifles in vehicles; later memos reiterated readiness expectations and allowed limited exceptions to on-site storage.
Operators say bringing gear home and storing parts inside residences (15 minutes) is necessary for mission-readiness and triggers the continuous-workday rule; City contends those tasks are preliminary/postliminary and excluded by the Portal-to-Portal Act and ECFA.
The district court granted summary judgment for the City, holding the loading/transport/storage tasks were not "integral and indispensable" to the principal activity and that no agreement existed to pay under the IWPCA; the Seventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether transporting/loading/unloading/storing SWAT gear to/from residences is compensable under the FLSA/IMWL as an "integral and indispensable" part of the principal activity (triggering continuous workday)	Bartlett: those off-duty tasks are intrinsic to rapid response and mission-readiness, so they are principal activities	City: tasks are preliminary/postliminary (two steps removed), commuting/vehicle use excluded by Portal-to-Portal and ECFA; alternative on-site arrangements exist	Held: Not integral and indispensable; tasks are preliminary/postliminary and excluded; summary judgment for City
Whether operators stated a valid IWPCA claim by showing an employment agreement (express or implied) to pay for the off-duty loading/transport/storage time	Bartlett: CBA overtime language, prior on-the-clock transfer time at work, and custom/practice imply pre-approval/agreement to compensate	City: CBA only covers "approved" overtime; no express or implicit agreement or consistent payment practice for these off-duty tasks; overtime requests were denied	Held: No specific express or implied agreement to pay for those off-duty tasks; IWPCA claim fails; summary judgment for City

Integrity Staffing Sols., Inc. v. Busk, 574 U.S. 27 (2014) ("integral and indispensable" test tied to the productive work an employee is employed to perform)
IBP, Inc. v. Alvarez, 546 U.S. 21 (2005) (preshift waiting time two steps removed from principal activity is not compensable)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946) (broad definition of worktime and continuous workday rule origins)
Tennessee Coal, Iron & R. Co. v. Muscoda Local No. 123, 321 U.S. 590 (1944) (early expansive definition of "work")
Steiner v. Mitchell, 350 U.S. 247 (1956) (donning/doffing and showering where required on premises can be integral and indispensable)
Mitchell v. King Packing Co., 350 U.S. 260 (1956) (knife-sharpening integral to meat-packing principal activity)
Sandifer v. U.S. Steel Corp., 571 U.S. 220 (2014) (continuous workday concept and principal activities interpretation)
Balestrieri v. Menlo Park Fire Protection Dist., 800 F.3d 1094 (9th Cir. 2015) (loading/unloading gear for firefighters held two steps removed and noncompensable)
Llorca v. Sheriff, Collier Cnty., Fla., 893 F.3d 1319 (11th Cir. 2018) (commute time in employer vehicle with incidental duties not indispensable)