## Facts

- Integrity Staffing Solutions supplied hourly workers to staff Amazon fulfillment warehouses.
- The workers’ primary duties were retrieving products from shelves and packaging them for shipment.
- After each shift, workers were required to wait for and undergo antitheft security screenings before leaving the warehouse.
- The screenings required employees to remove personal items and pass through metal detectors, with potential further inspection.
- Employees alleged the screening process took about 25 minutes per day.
- Employees sued for unpaid wages under the Fair Labor Standards Act (FLSA), as amended by the Portal-to-Portal Act, asserting the screening time was compensable work time.

## Issues

1. Whether time spent waiting to undergo and undergoing mandatory post-shift security screenings is compensable under the FLSA, as amended by the Portal-to-Portal Act, as an activity “integral and indispensable” to employees’ principal activities.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit.
- The Court held that time spent waiting for and undergoing the security screenings was not compensable under the FLSA as amended by the Portal-to-Portal Act.
- The Court reinstated dismissal of the employees’ FLSA claim.

## Legal Principles

- The Portal-to-Portal Act excludes compensation for activities that are “preliminary” or “postliminary” to an employee’s principal activities.
- “Principal activities” include tasks that are an “integral and indispensable” part of the employee’s main work.
- An activity is “integral and indispensable” only if it is an intrinsic element of the employee’s principal activities and one the employee cannot dispense with and still perform the principal work.
- Employer requirement and employer benefit, without more, do not make an activity compensable; otherwise, many excluded activities (e.g., commuting, timeclock procedures) would become compensable.
- Antitheft screenings aimed at loss prevention are not intrinsic to retrieving and packaging goods and are therefore noncompensable postliminary activities.

## Conclusion

The Court held that mandatory post-shift antitheft security screenings are not compensable work time under the FLSA/Portal-to-Portal Act because they are not intrinsic to, and not indispensable for, performing warehouse employees’ principal duties of retrieving and packaging products.


Integrity Staffing Sols., Inc. v. Busk, 574 U.S. 27 (2014)