February 5, 2026, the Connecticut Supreme Court unanimously ruled that employees must be compensated for time spent undergoing security screenings on their employer’s premises. The decision in Del Rio v. Amazon.com Services, Inc., overturns a 2023 U.S. District Court ruling which stated security screenings are not part of employee’s core job duties and are thus not compensable.
The decision has a significant impact on Connecticut employers because Connecticut offers greater protection than federal law on such matters.
Background
The case was brought by Connecticut Amazon warehouse workers in 2021 who had to complete pre-shift security screenings before entering and leaving the premises. These security checks ranged from a few seconds to 20 minutes and employees were not paid for this time.
The U.S. District Court ruled in favor of Amazon in their summary judgment. The Court held that these security screenings were not compensable under the Fair Labor Standards Act as they were not core job duties.
That decision was appealed to the U.S. Court of Appeals Second Circuit, who asked the Connecticut Supreme Court to clarify two pieces of Connecticut wage and hour law.
First, whether Connecticut law required employees to be compensated for time spent undergoing security screenings at their place of work. Second, whether a de minimis exception applied. A de minimis exception would exclude pay for an activity that is so limited it is unreasonable or impractical to record it as time worked.
Ruling
In answering the first question, the Connecticut Supreme Court referred to Connecticut General Statutes § 31-76b(2)(A). The court ruled “under Connecticut law, an employer must compensate its employers for all ‘hours worked,’ and the plain and unambiguous language of the statute… requires an employer to compensate its employees for any period of time during which the employer requires its employee to be on its premises, even if the employee is not required to work during that time period.”
As Amazon required warehouse workers to undergo these screenings on the premises before being allowed to leave at the end of their shift, “that time was compensable.”
The Court also clarified that there is no de minimis exception for compensability under Connecticut wage laws. Employers must pay even insubstantial or insignificant periods of time outside an employee’s scheduled work hours. The fact that such time cannot, “as a practical administrative matter, be precisely [or easily] recorded for payroll purposes” is irrelevant.
How Does This Effect Employers?
This decision impacts Connecticut employers who require security screenings or other mandatory activities at their work premises before and after employee shifts. The Connecticut Supreme Court’s explanation of “hours worked” may apply to activities beyond security screenings. Employers should review any other similar activities on their premises to ensure compliance.
Multi-state employers with Connecticut locations should remember Connecticut has stronger protection than federal law on this matter. To remain compliant in Connecticut, practices must reflect this higher standard.
Brody and Associates regularly advises management on compliance with the latest local, state and federal employment laws. If we can be of assistance in this area, please contact us at info@brodyandassociates.com or 203.454.0560.
