New England Biz Law Update
The 6th U.S. Circuit Court of Appeals has affirmed the dismissal of a Fair Labor Standards Act claim brought by a hospital security guard who alleged that he should have been compensated for meal breaks during which he was required to monitor his radio and remain available to respond to incidents.
The plaintiff, a nonexempt hourly employee, alleged that his employer automatically deducted 30 minutes for meal breaks but failed to account for time he was not fully relieved of duties.
He claimed that being required to monitor a radio and respond if needed made the time compensable, particularly when he worked more than 40 hours in a week.
A federal district court dismissed the complaint, and the 6th Circuit affirmed, finding that the allegations were insufficient to state a viable overtime claim.
The 6th Circuit explained that monitoring a radio and remaining available to respond, by itself, is not compensable under the FLSA. Instead, the key question is whether the employee is actually relieved of duty during the meal period.
The court emphasized that the complaint failed to allege how often, if at all, the plaintiff’s meal breaks were interrupted by work. Without factual allegations showing that the time was regularly or significantly interrupted, the claim could not proceed.
The decision reflects the principle that meal periods are not compensable if the employee is completely relieved from duty, and that limited or passive obligations during a break do not necessarily convert that time into paid work.
Lessons for employers on meal breaks
The ruling highlights that the compensability of meal periods depends on how the time is used in practice. Being required to remain available or monitor communications does not, on its own, make a meal period compensable.
At the same time, the decision indicates that frequent or meaningful interruptions to a meal period may still trigger compensation obligations under the FLSA.
Employers should review how meal breaks function in practice, not only how they are described in policy, with the following factors in mind:
- Requiring employees to remain reachable or monitor communications may be permissible, but regular interruptions can make that time compensable.
- Automatic meal break deductions should account for situations where employees are not fully relieved of duties.
- Supervisors should be trained to recognize when work during meal periods requires compensation.
- Employers should document expectations and practices to make clear that employees are generally able to take uninterrupted meal breaks.
