Sarrazin v. Coastal, Inc., 89 A.3d 841

Plaintiff Brian Sarrazin sought unpaid wages under Conn. Gen. Stat. §§ 31-60, 31-71b, 31-76c and regulation § 31-60-10(b), claiming commuting time was compensable.
Sarrazin used a company vehicle required by Coastal, Inc., which also stored some tools used at job sites.
Trial court found Coastal required use of the company vehicle but that its use conferred a benefit on Sarrazin and that tools stored in the vehicle were incidental to commuting; it denied recovery for commute time.
Majority concluded federal wage law preempted state regulation § 31-60-10 and relied on federal standards to resolve the claim.
Justice McDonald (joined by Justice Palmer) concurred: he agreed with rejecting deference to the department’s guidebook but would resolve the case under state law, interpreting § 31-60-10(b) to potentially cover some usual commutes when employer benefit and employee burden exceed de minimis levels.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 31-60-10(b) makes a usual commute compensable when employee performs services during commute	Sarrazin: § 31-60-10(b) can cover usual commute time when travel inures to employer and is incidental to employment	Coastal: commute time is noncompensable; subsections (c)/(d) show (b) does not apply to usual commute	Concurrence: § 31-60-10(b) can apply to usual commute in limited circumstances (employer obtains > de minimis benefit and employee incurs > de minimis burden); on facts, plaintiff not entitled because benefit to employee and tool storage were incidental
Whether federal law preempts state regulation as applied here	Sarrazin: state regulation provides broader protections and is not preempted	Coastal/majority: federal law governs; state rule cannot impose broader obligations inconsistent with FLSA	Majority: concluded federal law preempts state law for this claim; concurrence: disagreed — state regulation can provide equal or greater protection and is not preempted for these facts

Shell Oil Co. v. Ricciuti, 147 Conn. 277 (discussing "in the course of employment" in related contexts)
Morales v. PenTec, Inc., 57 Conn. App. 419 (addressing course-of-employment concepts)
Dombach v. Olkon Corp., 163 Conn. 216 (ordinary noncompensability of commute; exceptions when activity is incidental to employment)
Whitney v. Hazard Lead Works, 105 Conn. 512 (commute generally not in course of employment)
McNamara v. Hamden, 176 Conn. 547 (incidental-to-employment and employer-benefit exceptions)
Weems v. Citigroup, Inc., 289 Conn. 769 (wages linked to ascertainable efforts rendered for employer)
West v. Egan, 142 Conn. 437 (policy behind wage standards tied to value of services)
Labadie v. Norwalk Rehabilitation Servs., Inc., 274 Conn. 219 (travel may be in course of employment even if unpaid)
State v. AFSCME, AFL-CIO, Council 4, Local 2663, 257 Conn. 80 (ambiguity in remedial statutes resolved for protected class)
Tianti v. William Raveis Real Estate, Inc., 231 Conn. 690 (remedial-scheme ambiguity resolved in favor of employees)