Compensable Time Under the FLSA: Ruffin v. MotorCity

Barkan Meizlish , May 13, 2015

Last month, the Sixth Circuit Court of Appeals in Ruffin v. MotorCity Casino clarified the circumstances under which meal breaks are considered compensable under the Fair Labor Standards Act (“FLSA”).  In Ruffin, the security guard employees of MotorCity Casino argued that their 30 minute meal breaks should have counted as compensable working time because they were required to monitor their radios and respond to any emergencies that arose during their breaks.  Rejecting the security guards’ argument, the court affirmed the district court’s decision and held that MotorCity did not need to pay its employees for meal breaks.

Under the FLSA, time spent predominantly for the employer’s benefit constitutes compensable working time. The court in Ruffin examined three factors in the compensability analysis:

(1) Whether the employee performed any “substantial duties” during the meal period;

(2) Whether the employer’s business regularly interrupted the employee’s meal period;

(3) The employee’s inability to leave the employer’s property during the meal period.

In the analysis, the court cited to other cases that held that monitoring radios is not substantial enough to be considered compensable time.  The court noted that the guards introduced no evidence of regular emergency calls that interrupted their meal breaks, and specified that occasional interruptions are a di minimis activity insufficient to require compensation under the FLSA.

Branden Johnson, When is a Lunch Break Not a Lunch Break? The Sixth Circuit and Ruffin v. MotorCity Casino
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