Integrity Staffing Solutions, Inc. v. Busk, 574 U.S. ___, 2014 WL 6885951 (2014)

The employer in this case, Integrity Staffing Solutions, Inc., provides staffing to Amazon.com throughout the United States. Plaintiffs Jesse Busk and Laurie Castro worked as hourly employees retrieving and packaging products at Integrity Staffing warehouses in Nevada. Integrity Staffing required its employees to undergo a screening before leaving the warehouse at the end of each day. Busk and Castro filed a putative class action against Integrity Staffing on behalf of similarly situated employees for violations of Nevada state law and the federal Fair Labor Standards Act (“FLSA”), alleging they were entitled to compensation for time spent waiting to undergo and actually undergoing security screenings to prevent employee thefts at the end of their shifts – they alleged the screenings amounted to roughly 25 minutes per day. In a unanimous opinion, the United States Supreme Court held that the security screenings at issue here are “noncompensable postliminary activities” because the screenings were not the principal activity that the employees were employed to perform nor were they “integral and indispensable” to the employees’ duties as warehouse workers. See also Landers v. Quality Communications, Inc., 771 F.3d 638 (9th Cir. 2014) (putative FLSA class action was properly dismissed on the pleadings where plaintiff failed to allege facts showing there was a specific week in which he was entitled to but denied minimum or overtime wages).