745 F.3d 837
7th Cir.2014Background
- Plaintiffs at a Chicago poultry plant claim FLSA overtime and Illinois minimum wage overtime violations.
- District court granted summary judgment for employer and denied class certification for state-law claim.
- Line workers are unionized with a collective bargaining agreement; they perform deboning/evisceration along a moving line.
- Before work, during lunch, workers don, doff and wash sanitary gear; the central issue is whether lunch-break changing time is compensable under FLSA §203(o).
- Illinois regulations define hours worked broadly and include bona fide meal breaks; the Illinois Department of Labor treats meal periods as non-compensable if bona fide.
- The majority discusses de minimis and Supervisory guidance to justify nonprofit compensability debates; the dissent argues for broader compensation under Illinois law and direct application of §203(o).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether lunch-break donning/doffing is work time under FLSA §203(o). | Donning/doffing mid-day should be compensated. | Section 203(o) excludes this time when covered by a bona fide CBA. | Donning/doffing not compensable under 203(o) per majority. |
| Whether time spent changing during lunch is de minimis and thus non-compensable. | Time is not de minimis and should be paid. | Time is de minimis or excluded by 203(o). | Not de minimis under the majority’s reasoning; excluded by 203(o) or treated as de minimis avoided. |
| How Illinois Minimum Wage Act defines hours worked and its interaction with donning/doffing. | Illinois law requires compensation for on-premises changing during meal breaks. | Illinois law aligns with FLSA exemptions via regulation and de minimis approach. | Illinois law substantially broadens hours worked; savings clause allows more generous state treatment. |
| Whether the district court should have certified the state-law class or remanded for factual development. | Certification should proceed. | Class certification unnecessary given compensation framework. | Affirmed on the district court’s disposition (class certification not granted). |
Key Cases Cited
- Sepulveda v. Allen Family Foods, Inc., 591 F.3d 209 (4th Cir.2009) (donning and doffing during Bona fide meals matter; de minimis alternative grounds)
- Sandifer v. U.S. Steel Corp., 134 S. Ct. 870 (U.S.2014) (de minimis doctrine not favored; §203(o) bargaining focus)
- IbP, Inc. v. Alvarez, 546 U.S. 21 (U.S.2005) (continuous workday doctrine upheld for certain contexts)
- Porter v. Kraft Foods Global, Inc., 368 Ill.Dec. 737, 985 N.E.2d 310 (Ill.App. Dec. 10, 2013) (Illinois de minimis doctrine as applied to on-premises donning/doffing)
- Lewis v. Giordano's Enterprises, Inc., Ill.App.3d 581, 336 Ill.Dec. 884, 921 N.E.2d 740 (Ill.App.2009) (Illinois courts align with federal guidance in interpretation)