27 January 2014

Law in Plain English: Sandifer v. United States Steel Corporation

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

SCOTUSblogSandifer v. United States Steel Corporation

Argument: Nov 4 2013 (Aud.)

Background: The Fair Labor Standards Act (FLSA), 29 U.S.C. § 203(o), excludes, from the time during which an employee is entitled to be compensated at the minimum hourly wage "any time spent in changing clothes...at the beginning or end of each workday which was excluded from measured working time...by the express terms of or by custom or practice under a bona fide collective-bargaining agreement applicable to the particular employee." A group of workers at U.S. Steel filed a collection action lawsuit against the company for failing to compensate them for the time they spent putting on and taking off their work clothes in a locker room at the plant. The clothes consist of flame-retardant pants and jacket, work gloves, metatarsal boots (work boots containing steel or other strong material to protect the toes and instep), a hard hat, safety glasses, ear plugs, and a "snood" (a hood that covers the top of the head, the chin, and the neck). The District Court ruled that the FLSA does not require that the clothes-changing time in this case be compensated, and the Seventh Circuit agreed.

Issue: The question before the Court is what constitutes “changing clothes” within the meaning of Section 203(o) of the FLSA?

Holding: In a unanimous decision (except for Justice Sotomayor, who did not join in footnote 7), the Supreme Court ruled that most of the items identified by the workers were indeed clothes, and as a result, the time that petitioners spend donning and doffing their protective gear is not compensable by the operation of federal law. Consequently, the FLSA does not require that the clothes-changing time in this case be compensated and the Seventh Circuit's decision was affirmed.

Gary Works, U. S. Steel’s largest manufacturing plant, is situated on the south shore of Lake Michigan.
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