Sandra Babcock v. Butler County, 806 F.3d 153

Plaintiff Sandra Babcock, a Butler County corrections officer, sued on behalf of similarly situated officers alleging a 15‑minute unpaid portion of a one‑hour meal period should be compensable under the FLSA as overtime.
Officers work 8.25‑hour shifts that include a 1‑hour meal period: 45 minutes paid, 15 minutes unpaid per the collective bargaining agreement (CBA).
During the meal period officers must remain on prison premises (unless authorized to leave), in uniform, near emergency equipment, and available to respond immediately to incidents; plaintiffs allege these constraints severely limit personal activities.
Defendant moved to dismiss under Rule 12(b)(6), arguing the unpaid 15 minutes are not compensable because the meal period predominantly benefits the officers (not the employer); District Court dismissed the complaint.
On appeal the Third Circuit adopted the "predominant benefit" test for meal‑period compensability and affirmed dismissal, finding the totality of facts alleged did not show the unpaid 15 minutes were predominantly for the employer’s benefit.
A divided panel: the majority considered the CBA and related facts significant; the dissent argued dismissal was premature given fact‑intensive inquiry and that the complaint plausibly alleged compensable work.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a portion of meal period is compensable under FLSA	The 15‑minute unpaid period is compensable because officers remain on site, in uniform, and ready to respond, so the time is primarily for employer’s benefit	The meal period predominantly benefits the officers (partially paid; may request leave; CBA provides overtime if interrupted), so unpaid 15 minutes not compensable	Affirmed dismissal: unpaid 15 minutes not compensable under predominant‑benefit test
Appropriate legal standard for meal‑period compensability	(alternative) apply "completely relieved from duty" test or predominant benefit test	Predominant benefit test is appropriate and customary in circuits	Court adopts predominant benefit test (totality‑of‑circumstances inquiry)
Effect of the CBA on FLSA claim	CBA cannot preclude FLSA rights; reliance on CBA alone is insufficient to defeat claim	CBA terms (partial pay, overtime if interrupted) are relevant evidence that officers receive predominant benefit	CBA is a relevant but not dispositive factor; here it supported finding no predominance of employer benefit
Procedural question whether dismissal on pleadings was proper	Dissent: complaint plausibly alleges facts that require discovery; dismissal premature	Majority: allegations, the CBA in the record, and precedent permit decision on pleadings	Majority: Rule 12(b)(6) dismissal affirmed; dissent would have allowed discovery/amendment

Armour & Co. v. Wantock, 323 U.S. 126 (1944) (whether time is predominantly for employer or employee depends on all circumstances)
Skidmore v. Swift & Co., 323 U.S. 134 (1944) (agency interpretive regulations are persuasive but not controlling; determine "work" by totality of circumstances)
Reich v. Southern New England Telecommunications Corp., 121 F.3d 58 (2d Cir. 1997) (meal period compensable where on‑site presence during meals served employer’s security needs)
Alexander v. City of Chicago, 994 F.2d 333 (7th Cir. 1993) (meal‑period compensability is fact‑specific; CBA is one factor among many)
Bernard v. IBP, Inc. of Neb., 154 F.3d 259 (5th Cir. 1998) (adopts predominant‑benefit approach to meal‑period compensation)
Leahy v. City of Chicago, 96 F.3d 228 (7th Cir. 1996) (CBA considered to protect FLSA rights; court discussion noted but treated as distinguishable and not controlling here)