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Demetrio v. Sakuma Bros. Farms, Inc., 2015 Wash. LEXIS 807 (Wash. July 16, 2015)

Articles Discussing Case:

Washington High Court: Piece Rate Compensation Alone Does Not Satisfy Rest Break Pay Requirement

Jackson Lewis P.C. • July 24, 2015
The Washington Supreme Court has ruled that employers must provide agricultural piece rate workers with extra compensation for their rest periods, rejecting the employer’s argument that its piece rate already included compensation for the required rest periods. Demetrio v. Sakuma Bros. Farms, Inc., 2015 Wash. LEXIS 807 (Wash. July 16, 2015).

Washington Piece-Rate Workers to Receive Separate Rest Breaks

Littler Mendelson, P.C. • July 24, 2015
The expansive interpretation of meal and rest break regulations continues in Washington State, as the state's highest court ruled in Demetrio v. Sakuma Brothers Farms, Inc., Case No. 90932-6 (Wash. Sup. Ct. July 16, 2015), that agricultural piece-rate workers are entitled to separate paid rest breaks. The court reasoned that hourly workers remain "on the clock" during rest breaks, and thus piece-rate workers should receive the same treatment.

Washington Employers Must Pay Piece Rate Workers Additional Rest Break Compensation

Fisher Phillips • July 24, 2015
With some limited exceptions, Washington State wage and hour rules require that workers receive a paid 10 minute rest break for every four hours worked. The Washington Supreme Court has now expanded employer obligations in this regard by ruling that employers must pay piece rate workers additional compensation for the required rest periods. The July 16, 2015 decision in Demetrio v. Sakuma Brothers Farms, Inc. states that the rest break time cannot be folded into the piece rate, and instead must be paid separately. While this case arose in the agricultural-worker context, its key holding likely applies to all industries that use piece rate compensation plans – plans under which an employee’s pay is based on the number of “pieces” he or she generates or completes.

Washington’s Highest Court Rules Piece Rate Compensation Does Not Satisfy Rest Break Pay Requirement

Jackson Lewis P.C. • July 22, 2015
Like all compensation methods, piece rate compensation plans – under which an employee is compensated based on the number of “pieces” he or she generates or completes – must be analyzed for wage-and-hour compliance. For example, under federal law, minimum wage generally is due for all hours worked, and there are recordkeeping obligations, although some piece rate plans may qualify for the section 7(i) overtime exemption. Under state law, employers also must analyze whether piece rate employees’ compensation meets all applicable requirements, which supplement FLSA requirements for most employers. A new decision from Washington state’s highest court reinforces this last principle and imposes further payment obligations on certain Washington employers. Demetrio v. Sakuma Bros. Farms, Inc., 2015 Wash. LEXIS 807 (Wash. July 16, 2015).