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21 Dec 2015

PHILADELPHIA — A federal appeals court decided against a group of corrections officers who worked at a county prison in Pennsylvania who filed a class action against the state for alleged violations of the Fair Labor Standards Act (FLSA). The officers claimed that they should have been paid for 15 minutes of an hour-long meal period, but the appeals court disagreed. This court, the Third Circuit Court of Appeals, joined other federal appeals courts across the country in adopting what is called the “predominant benefit” test in deciding whether employee time is compensable under FLSA.

Predominant Benefit Test

The court in this case used a “predominant benefit” test to determine if the officers’ meal time must be paid under FLSA. According to that test, whether or not time is compensable depends on whether the officer is primarily engaged in work-related duties during the meal periods and not primarily for the employee’s benefit. The officers argued that they should be paid under this test because they were not allowed to leave the prison without the warden’s special permission, were required to keep emergency equipment within reach and were mandated to respond immediately to emergency calls during meal periods. Under these circumstances, according to the plaintiffs, the meal periods were not really free time for employees.

Union Contract is Relevant

The court disagreed with the plaintiffs. Analyzing the totality of the circumstances, the court found that the restrictions placed on the corrections officers during their meal periods did not primarily benefit the employer. They were allowed to request authorization to leave the prison for their meal period and could eat lunch away from their desks. Additionally, the court found the union contract provided the officers with sufficient protection – it gave the officers the benefit of a partly compensated mealtime and mandatory overtime pay if their mealtime is interrupted by work. Under the contract, the officers were paid for 45 minutes of the meal period and were only paid for the final 15 minutes if they had to respond to a prison emergency. Otherwise, they were not paid if the final 15 minutes remained uninterrupted employee time. According to the court, the union contract assumes that an officer is generally not working during a meal period, but requires payment when an officer actually does work during the meal.

Whether or not time spent by employees is compensable under FLSA is a complex inquiry that requires an analysis of all of the circumstances surrounding a case. You should call (855) 754-2795 or complete the Free Unpaid Overtime Case Review form on the top right of this page if you feel that you have a valid wage claim. Our top-rated team of wage lawyers will evaluate your situation to determine your best course of action. We will also determine if it is in your best interest to file a lawsuit against your employer. There are strict time limitations for filing, so it is important that you call our experienced attorneys today.

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