On April 17, 2015, the U.S. District Court for the Northern District of California in Miranda v. Coach, Inc., 2015 U.S. Dist. LEXIS 51768 struck a strong blow against any argument that the exclusion for the time an employee spends undergoing post-shift security screenings from their hours worked under the federal Fair Labor Standards Act (FLSA) also applies to similar claims under California’s wage and hour laws. In Miranda, the plaintiffs alleged the defendant had a policy requiring that all sales representatives submit to an uncompensated security screening of their bags, jackets, purses, and other items each time they left the store and this cut into their rest breaks and meal periods, as well as required them to remain at work past the end of their shift. The defendant moved to dismiss the Complaint arguing, in part, that the plaintiffs’ claims were barred by the United States Supreme Court’s decision in Integrity Staffing Solutions, Inc. v. Busk, 135 S.Ct. 513 (2014), which held that time an employee spent undergoing such post-shift security screenings was not compensable under the FLSA.
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