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IBP, Inc. v. Alvarez

546 U.S. 21, 126 S.Ct. 514, 163 L.Ed.2d 288, Web 2005 U.S. Lexis 8373 (2005)

Supreme Court of the United States

“The relevant text describes the workday as roughly the period from ‘whistle to whistle.’”

—Stevens, Justice

Facts

IBP, Inc., produces fresh beef, pork, and related meat products. At its plant in Pasco, Washington, it employed approximately 178 workers in its slaughter division and 800 line workers. All workers must wear gear such as outer garments, hardhats, earplugs, gloves, aprons, leggings, and boots. IBP requires employees to store their equipment and tools in company locker rooms, where the workers don and doff their equipment and protective gear.
The pay of production workers is based on time spent cutting and bagging meat. Pay begins with the first piece of meat and ends with the last piece of meat. IBP employees filed a class action lawsuit against IBP to recover compensation for the time spent walking between the locker room and the production floor before and after their assigned shifts. The employees alleged that IBP was in violation of the Fair Labor Standards Act (FLSA).
The U.S. district court held that the walking time between the locker room and the production floor was compensable time and awarded damages. The U.S. court of appeals affirmed the district court’s decision. IBP appealed. The U.S. Supreme Court granted a writ of certiorari to hear the appeal.

Issue

Is the time spent by employees walking between the locker room and production area compensable under the Fair Labor Standards Act?

Language of the U.S. Supreme Court

The Department of Labor has adopted the continuous workday rule, which means that the “workday” is generally defined as the period between the commencement and completion on the same workday of an employee’s principal activity or activities. The relevant text describes the workday as roughly the period from “whistle to whistle.” Moreover, during a continuous workday, any walking time that occurs after the beginning of the employee’s first principal activity and before the end of the employee’s last principal activity is covered by the FLSA.

Decision

The U.S. Supreme Court held that the time spent by employees walking between the locker room and the production areas of the plant was compensable under the Fair Labor Standards Act.

Ethics Questions

Was this the type of situation that the FLSA was meant to address? Was it ethical for IBP not to pay its employees for the time challenged in this case?