Ruffin v. MotorCity Casino, No. 14-1444 (6th Cir. 2015)
Annotate this CaseSecurity guards at MotorCity Casino sued under the Fair Labor Standards Act overtime provision, 29 U.S.C. 207(a). They claimed they worked five, eight-hour shifts per week, escorting cash, monitoring the casino floor, and listening to two-way radios. They were required to attend an uncompensated 15-minute meeting before every shift. A guard working an eight-hour shift was entitled to a paid, 30-minute meal period. Guards could not leave casino property, have food delivered, or receive visitors; they spent meal periods in a cafeteria, where free food and drinks were available, or walking along an outdoor path. Guards had to listen to their radios and, if they heard the code, respond to an emergency. Guards who lost meal time responding to an emergency were entitled to have the time made up. Emergencies rarely interrupted meal periods. Guards had to focus on the radio chatter to know if an emergency required occurred, but were able to eat, socialize, and use their phones. The court held that meal periods were non-compensable, that monitoring the radio was a de minimis activity, not a substantial job duty, and that MotorCity could offset paid meal time against time in unpaid, but compensable, meetings. The Sixth Circuit affirmed. No reasonable jury could find that the meal periods predominantly benefitted the casino.
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