Troester v. Starbucks Corp.Annotate this Case
The Supreme Court accepted the Ninth Circuit’s request for certification and answered (1) California’s wage and hour statutes and regulations have not adopted the de minimis doctrine found in the federal Fair Labor Standards Act (FLSA); and (2) the relevant wage order and statutes do not permit application of the de minimis principle on the facts of this case.
Here, an employer required an employee to work “off the clock” for several minutes per shift. The employer moved for summary judgment on the ground that the employee’s uncompensated time was so minimal that the employer was not required to compensate him. The district court concluded that the de minimis doctrine applied and granted summary judgment for the employer. On appeal, the Ninth Circuit asked the Supreme Court to answer whether the FLSA’s de minimis doctrine applies to claims for unpaid wages under California Labor Code sections 510, 1194, and 1197. The Supreme Court held (1) the pertinent statutes and wage order have not incorporated the de minimis doctrine set forth in the FLSA; and (2) while California has a de minimis rule that has operated in various contexts, that rule is not applicable under the facts of this case.