Sandifer v. United States Steel Corp.
134 S. Ct. 870
| SCOTUS | 2014Background
- Petitioners seek backpay under FLSA for time spent donning/doffing protective gear as required by employer hazards.
- Respondent contends that this time is noncompensable under §203(o) due to a collective-bargaining agreement.
- District Court granted summary judgment for respondent, concluding gear time was changing clothes under §203(o) and de minimis for non-clothes items.
- Seventh Circuit affirmed the noncompensability and limited_doubt about respirators.
- Court grants certiorari and affirms judgment, holding donning/doffing protective gear falls within §203(o) or not depending on clothes definition.
- Court clarifies interpretation to avoid broad, unfettered application of de minimis and to defer to bargaining over time spent changing clothes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of §203(o) applicability | Sandifer argues donning/doffing is compensable. | U.S. Steel argues time is noncompensable under §203(o) due to bargaining. | §203(o) applies to time changing clothes. |
| Meaning of 'clothes' in §203(o) | Protective gear is not 'clothes.' | Protective gear may be 'clothes' if designed/used to cover the body. | 'Clothes' means items designed/used to cover the body; many protective items qualify, some do not. |
| Meaning of 'changing' | 'Changing' means substitution only. | 'Changing' includes altering dress. | 'Changing' includes altering dress; not limited to substitution. |
| Role of de minimis doctrine | De minimis should reduce nonclothes time. | De minimis may excuse trifles. | De minimis not readily applicable; focus on whether majority time is spent on clothes. |
Key Cases Cited
- Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (U.S. 1946) (expanded view of 'work' under FLSA and set context for time spent on preliminary activities)
- Steiner v. Mitchell, 350 U.S. 247 (U.S. 1956) (allowed§203(o) to apply where clothes are integral to principal activity)
- IBP, Inc. v. Alvarez, 546 U.S. 21 (U.S. 2005) (applied Steiner to donning/doffing of protective gear; discussed principal activity concept)
- Sepulveda v. Allen Family Foods, Inc., 591 F.3d 209 (4th Cir. 2009) (de minimis analysis in clothing-change context; cited by Court)