The panel affirmed the district court’s judgment on the pleadings in favor of Defendants Amazon.com Services, Inc. and Amazon.com, Inc., in a class action alleging that Defendants’ failure to compensate employees for time spent waiting for and passing through mandatory security screenings before and after work shifts and off-premises meal breaks violated Oregon’s wage and hour laws.
The panel had certified the following issue to the Oregon Supreme Court: “Under Oregon law, is time that employees spend on the employer’s premises waiting for and undergoing mandatory security screenings compensable?” In response, the Oregon Supreme Court held that Oregon law aligns with federal law regarding what activities are compensable. Therefore, time that employees spend on the employer’s premises waiting for and undergoing mandatory security screenings before or after their work shifts is compensable only if the screenings are either (1) an integral and indispensable part of the employees’ principal activities, or (2) compensable as a matter of contract, custom, or practice.
Plaintiff’s complaint did not allege that either of the identified exceptions applied. Accordingly, the panel held that the district court properly granted judgment on the pleadings to Defendants. Although the Oregon Supreme Court’s opinion did not address separately or directly Plaintiff’s meal-period claim, the logic of that opinion yielded the same result. Under both federal and state law, the test is whether an employee performed work duties during the meal period. And under both Oregon and federal regulations, employees on meal breaks must be relieved from duty. Because the Oregon Supreme Court squarely held that Oregon law aligns with federal law regarding what activities are compensable and because Plaintiff failed to allege that undergoing a mandatory security screening was “an integral and indispensable part” of an employee’s principal activities, her claim failed.