Connecticut Supreme Court Rules Screening Time Must Be Paid

Quick Hits

• On February 10, 2026, the Connecticut Supreme Court held that mandatory security screening time on employer premises must be compensated under Connecticut General Statutes § 31-76b(2)(A), which defines “hours worked” to include “all time during which an employee is required by the employer to be on the employer’s premises.”
• Although the court did not purport to address every conceivable situation where the de minimis rule may apply, it stated strongly that Connecticut’s wage laws do not include an exception that would allow employers to disregard small increments of compensable time.
• The decision establishes that Connecticut’s wage laws are more protective than the federal FLSA, which does not require compensation for postliminary security screenings.

Background

Javier Del Rio, Colin Meunier, and Aaron Delaroche were warehouse workers at Amazon fulfillment centers in Windsor and North Haven between 2018 and 2021. At the conclusion of each shift, Amazon required employees to pass through a metal detector before leaving the building. Depending on whether employees carried personal items, they were routed through one of three screening processes: express lanes (no delay), divesting tables (for items like keys and wallets), or X-ray machines (for bags and lunch boxes). If an alarm sounded, a second screening with a hand-held metal detector was required.

The screenings typically ranged in time from a few seconds to several minutes, though employees testified that wait times occasionally extended to ten or even twenty minutes. Employees clocked out before going through security, meaning they were not compensated for screening time.

The plaintiffs filed a putative class action complaint in Connecticut Superior Court in August 2021, alleging that Amazon violated Connecticut wage laws by failing to pay employees for time spent undergoing these mandatory security procedures. Amazon removed the case to the U.S. District Court for the District of Connecticut under the Class Action Fairness Act.

The district court granted summary judgment for Amazon, concluding that Connecticut’s wage laws should be interpreted consistently with federal law. Specifically, under a 2014 decision issued by the Supreme Court of the United States, security screenings are noncompensable “postliminary activities” under the FLSA because they are “not ‘integral and indispensable’” to employees’ principal warehouse duties.

The plaintiffs appealed, and the Second Circuit determined that the case raised unresolved questions of Connecticut state law. The Second Circuit then certified two questions to the Connecticut Supreme Court: (1) whether Connecticut wage laws require compensation for mandatory security screening time, and (2) whether a de minimis exception applies.

Analysis

The Connecticut Supreme Court began its analysis by reviewing the plain language of § 31-76b(2)(A), which defines “hours worked” as “all time during which an employee is required by the employer to be on the employer’s premises.” The statute expressly includes waiting time, even “when an employee is required to wait on the premises while no work is provided by the employer.”

Amazon contended the statute was ambiguous because it does not define “work.” The court rejected this argument, holding that the meaning of “work” is irrelevant to compensability under the plain statutory text. The phrase “hours worked” is expressly defined to include time an employee is required to be on premises, regardless of whether work is being performed. Because Amazon required employees to remain on-site during security screenings, that time was compensable.

The Connecticut Supreme Court contrasted Connecticut’s wage laws with federal law. According to the Supreme Court’s 2014 ruling, under the federal FLSA as amended by the Portal-to-Portal Act, security screenings are noncompensable “postliminary activities” because they are not “integral and indispensable” to employees’ principal duties. But the Connecticut Supreme Court noted that FLSA establishes only a “national floor.” States remain free to enact wage laws more protective than the federal standard, and, according to the court, Connecticut has done that by defining “hours worked” to include all time employees are required to be on employer premises.

Amazon argued that such a broad reading of Connecticut’s wage laws would produce absurd or unworkable results because employers cannot track every moment employees spend on premises. The court was unpersuaded, observing that Amazon could simply relocate its time clocks outside the security area. The court also emphasized that policy judgments about costs and benefits belong to the legislature, not the courts.

Finally, the court rejected a de minimis exception that would apply to Amazon’s security screenings. In other words, Connecticut law did not permit Amazon to disregard trivial amounts of time spent by the employees engaging in the screenings.

Next Steps for Employers

In light of the Del Rio decision, Connecticut employers may want to consider reviewing their practices in Connecticut, including as follows:

• Employers requiring any post-shift activities on premises may want to evaluate whether employees are appropriately compensated for that time. If employees are not clocked in during certain required activities, employers may face liability.
• Employers may want to explore whether certain pre- or post-shift requirements can be restructured to minimize required time at the work location, including by potentially streamlining screening processes.
• The Connecticut Supreme Court pointed out that employers with security screening or other exit procedures could presumably place time clocks outside the screening area so employees clock out after completing the process
• Unlike under federal law, Connecticut employers arguably cannot dismiss wage claims as de minimis simply because the uncompensated time is brief. Employers may want to consider reviewing all practices to determine whether employees are paid for all always worked.

Ogletree Deakins’ Stamford office and Wage and Hour Practice Group will continue to monitor developments and will post updates on the Class Action, Connecticut, Trucking & Logistics, and Wage and Hour blogs as additional information becomes available.

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