Heimbach v. Amazon.com, No. 18-5942 (6th Cir. 2019)

Annotate this Case
Justia Opinion Summary

Plaintiffs were hourly workers at an Amazon fulfillment center. After clocking out, they were required to undergo an anti-theft security screening. They were not compensated for the time spent in the screening process. The district court rejected a purported class action under the Pennsylvania Minimum Wage Act (PMWA), citing the Supreme Court’s 2014 “Busk” decision. Busk interpreted the Fair Labor Standards Act (FLSA), 29 U.S.C. 201, and the Portal-to-Portal Act, 29 U.S.C. 250 to find post-shift security screening non-compensable. The Sixth Circuit certified two questions to the Pennsylvania Supreme Court: Is the time spent on an employer’s premises waiting to undergo and undergoing mandatory security screening compensable as “hours worked” under the PMWA; Does the doctrine of de minimus non curat lex bar claims brought under the PMWA? The U.S. Supreme Court has applied the doctrine to the FLSA, to hold that employers are not required to compensate employees for small amounts of time that are administratively difficult to track.

Primary Holding
Sixth Circuit certifies, to the Pennsylvania Supreme Court, questions concerning the compensability of time spent on post-shift security screening under state law.

Disclaimer: Justia Annotations is a forum for attorneys to summarize, comment on, and analyze case law published on our site. Justia makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship.