Second Circuit: Amazon Connecticut Security Pay Class Action Reinstated

• The Second Circuit Court of Appeals revived a class action lawsuit by Amazon workers in Connecticut seeking pay for mandatory security screenings.
• The ruling follows a Connecticut Supreme Court decision clarifying that mandatory security screenings on employer premises are compensable 'hours worked' under state law.
• Connecticut wage laws do not include a de minimis exception, meaning even brief mandatory screening times must be compensated.
• Amazon's defense, based on the federal Portal-to-Portal Act, was effectively countered by the state court's interpretation of Connecticut wage law security screening requirements.
• The case will now return to a Connecticut federal court, but the ruling's impact is limited to workers within Connecticut.

The Connecticut Supreme Court definitively ruled that any time an employer mandates its employees to spend undergoing security screenings on company premises is considered compensable 'hours worked' under state statutes.

In a significant development for labor rights in Connecticut, a federal appeals court recently reinstated a class action lawsuit filed by Amazon employees seeking compensation for time spent undergoing mandatory security screenings. The Second Circuit Court of Appeals ruled this week that three Connecticut-based Amazon workers can proceed with their claim for millions in backpay, overturning a lower court's dismissal of the case.

The lawsuit, originally filed in 2021, alleges that Amazon unlawfully denied pay to workers for the time they were required to spend in metal detection lines when exiting company warehouses. These security checks, implemented by Amazon to prevent merchandise theft, reportedly consumed between 10 and 20 minutes per screening, potentially adding up to 50 to 90 minutes of uncompensated time each week for employees. A U.S. District Court in Connecticut had initially dismissed the case in 2023, siding with Amazon's arguments.

However, the Second Circuit's decision provides a new opportunity for the workers, finding that a recent ruling by the Connecticut Supreme Court directly contradicts Amazon's previous legal positions. This appellate panel's determination paves the way for the case to return to the Connecticut federal court, where it will undergo further proceedings consistent with the state's highest court's interpretation of wage laws.

The Second Circuit's reversal hinges on crucial clarifications provided by the Connecticut Supreme Court earlier this year. The federal appeals court had previously certified two specific questions to the state's highest judicial body to ascertain the precise scope of Connecticut wage law regarding mandatory activities. The Connecticut Supreme Court definitively ruled that any time an employer mandates its employees to spend undergoing security screenings on company premises is considered compensable 'hours worked' under state statutes.

Crucially, the state court also concluded that Connecticut wage laws do not incorporate a de minimis exception to compensability. This means that even brief periods of mandatory activity, such as the security screenings at Amazon facilities, must be compensated. Consequently, the Second Circuit determined that any duration Amazon employees were required to spend in these mandatory security screenings, regardless of how short, is compensable under Connecticut law, directly impacting the ongoing Amazon worker class action Connecticut.

Amazon had initially argued for dismissal based on the federal Portal-to-Portal Act of 1947, citing a 2014 U.S. Supreme Court precedent that exempts employers from compensating workers for 'preliminary' and 'postliminary' activities. However, the Connecticut Supreme Court's interpretation of state law now takes precedence for this specific claim, establishing a different standard for compensable time Connecticut employers must adhere to.

With the Second Circuit's ruling, the case will now be remanded to the Connecticut federal court, where U.S. District Judge Kari Dooley, who originally dismissed the lawsuit, will preside over further proceedings. Amazon had also attempted to argue on appeal that employees themselves often prolonged the security screening process by bringing personal belongings into the workplace, suggesting that without such items, workers could pass through without delay. The Second Circuit, however, declined to rule on this specific point, noting that Amazon raised it for the first time during the appeal, though the company is free to present this argument upon remand.

It is important to note that the impact of this ruling on mandatory screening pay Connecticut is localized. While a significant victory for the Amazon workers involved, the decision applies exclusively to employees within Connecticut. Federal law does not currently mandate that employers compensate workers for time spent in security screening lines, meaning this precedent does not extend beyond the state's borders. The appellate panel that issued this week's decision included U.S. Circuit Judges Joseph Bianco, Eunice Lee, and Myrna Perez.

This ruling clarifies that under Connecticut law, mandatory security screenings are compensable 'hours worked' regardless of duration, rejecting the de minimis exception. Employers operating in Connecticut must review their policies regarding uncompensated time for mandatory activities like security screenings to avoid wage and hour litigation and ensure compliance with state wage laws.

Source: Original reporting via The Associated Press