Sixth Circuit: Time Spent Monitoring Radios During Meal Periods Not Compensable under the FLSA

In a significant decision addressing the compensability of employee break times, the U.S. Court of Appeals for the Sixth Circuit recently held that time spent by a group of security guards monitoring their radios during meal periods was not compensable work time under the FLSA because they failed to demonstrate that the time spent during their meal breaks was predominantly for the benefit of their employer. Notably, the Sixth Circuit found that the meal periods were non-compensable notwithstanding the fact that the security guards were unable to leave the premises and had to listen to their radio throughout their break, regardless of what they were doing.