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Sandifer v. U.S. Steel Corp (US 2014)

Articles Discussing Case:

Supreme Court Tackles FLSA’s Clothes-Changing Rule

Phelps Dunbar LLP • January 29, 2014
The Supreme Court has decided an important wage-and-hour case for employers with unionized workforces. In Sandifer v. U.S. Steel Corp, a collective-bargaining agreement provided that time spent changing clothes at the beginning and end of each work day was noncompensable. Members of the collective-bargaining unit sought a ruling that the “donning” and “doffing” of certain protective gear did not qualify as “changing clothes” and thus required wage payments for the time spent in such activities.

Supreme Court Rules “Changing Clothes” Is Not Compensable Under Plant Workers’ Union Contract

Ogletree Deakins • January 28, 2014
On January 27, in a very limited ruling, the Supreme Court of the United States held that an employer was not required to pay union employees for the time it takes them to put on and take off protective gear when their collective bargaining agreement did not provide for compensation for that time. After analyzing whether the workers’ protective gear qualifies as “clothes,” the Court held that, under the union contract between the parties, the time that the employees spent donning and doffing their protective gear was not compensable under section 203(o) of the Fair Labor Standards Act (FLSA). The decision, which was unanimous (except that Justice Sotomayor did not join in footnote 7), affirms the Seventh Circuit Court of Appeals’ 2012 ruling and reinforces employers’ ability to negotiate the compensability of such activities through a collective bargaining agreement. For nonunion employers, this ruling does not change the donning and doffing rules under the FLSA. Sandifer v. United States Steel Corp., No. 12-417, Supreme Court of the United States (January 27, 2014).

Supreme Court Clarifies Meaning Of "Changing Clothes" Under The Fair Labor Standards Act

Fisher Phillips • January 28, 2014
On January 27, 2014, the U.S. Supreme Court held that the time spent by employees donning and doffing (putting on and taking off) certain protective gear is not compensable under Section 203(o) of the Fair Labor Standards Act (FLSA). This ruling will significantly impact the ability of employees to seek compensation for the donning and doffing of certain items in the unionized setting. Additionally, the Court made comments about the de minimis doctrine which could well impact employers in the nonunionized environment. Sandifer v. United States Steel Corp.

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