Table of Contents

1. Key Highlights:
2. Introduction
3. Del Rio v. Amazon: Facts, Claims, and the Court’s Holding
4. The Statutory Foundation: How Connecticut Defines “Hours Worked”
5. The De Minimis Doctrine: Federal Origins and Connecticut’s Rejection
6. How This Ruling Differs from Federal Practice and Other Jurisdictions
7. Practical Scenarios: What Time Must Be Paid Under Del Rio?
8. The Scale of Exposure: How Small Periods Add Up
9. Operational Impacts: Timekeeping, Policies, and On-Site Procedures
10. Litigation and Class-Action Risk: Why Employers Should Take Notice
11. Steps Employers Should Take Now: A Practical Compliance Roadmap
12. Examples and Illustrations: How Employers Might Apply the Ruling
13. Employee Perspective: What Workers Should Know and Do
14. Broader Implications: Technology, Surveillance, and Labor Practices
15. Potential Legislative and Regulatory Responses
16. How This Decision Affects Multi-State Employers
17. Enforcement Landscape: Agency Action and Private Litigation
18. Practical Draft Policies: Sample Language Employers Can Use
19. When Employers May Lawfully Avoid Payment
20. Steps for Employees Seeking Redress
21. Anticipating Employer Arguments Post-Del Rio
22. Cost-Benefit Considerations: Paying for Minutes vs. Redesigning Procedures
23. Looking Ahead: Employer Practices Likely to Change
24. FAQ

Key Highlights:

• Connecticut’s highest court held in Del Rio v. Amazon.com Services, Inc. that employees must be paid for time spent undergoing employer-required post-shift security screenings; the state does not recognize the federal “de minimis” exception.
• The decision interprets Connecticut statutes defining “hours worked” to include time employees are required to wait on the employer’s premises and clarifies that any duration of compensable work must be paid, exposing employers to increased wage liability and class-action risk if they fail to pay brief but required tasks.

Introduction

On February 10, 2026, the Connecticut Supreme Court issued a decision that will reshape how employers account for brief on-premises activities at the beginning and end of a shift. In Del Rio v. Amazon.com Services, Inc., 354 Conn. 151 (2026), the Court held that time spent by Amazon warehouse employees undergoing security screenings at the end of their scheduled shifts is compensable under Connecticut wage laws. Equally significant, the Court declined to import the federal de minimis doctrine—under which minor, difficult-to-record periods of work may sometimes be disregarded for wage purposes—into Connecticut law. The ruling underscores that, in Connecticut, even very short periods of employer-required activity are treated as hours worked and must be paid.

This decision matters for any employer that requires employees to remain on-site after their scheduled shift for security checks, equipment returns, cleaning, or other tasks that may take only a few seconds to several minutes. It also signals a narrower route for employers to rely on regulatory exceptions when state statutes set their own definitions of compensable time. The following analysis unpacks the decision, explains the statutory basis, surveys practical implications for employers and workers, and offers concrete compliance steps to limit wage-and-hour exposure.

Del Rio v. Amazon: Facts, Claims, and the Court’s Holding

Three Amazon fulfillment center employees in Connecticut filed a class action alleging that Amazon failed to compensate them for time spent in end-of-shift security screenings between 2018 and 2021. The screenings were imposed by Amazon and took place after employees had completed their scheduled shifts. Testimony and evidence showed the per-employee screening time varied widely—some screenings lasted only seconds, while others extended up to 20 minutes, particularly when an employee carried personal items such as a backpack, lunch container or purse.

Plaintiffs sought wages for the time spent waiting on-site and undergoing the screenings. Amazon defended on two grounds: first, that such screening time was not “hours worked” under Connecticut law; second, that even if it was compensable, the time constituted a de minimis period that the employer could lawfully disregard under the doctrine applied in certain federal wage cases and federal regulations.

The Connecticut Supreme Court reached two central conclusions:

1. Connecticut statutory law requires payment for the time at issue. Under Conn. Gen. Stat. § 31-71b, employers must pay wages based on hours worked. The Court read the definition of “hours worked” in Conn. Gen. Stat. § 31-76b(2)(A) to include “all time during which an employee is required by the employer to be on the employer’s premises or to be on duty,” explicitly encompassing time when an employee is required to wait on the premises while no work is provided.
2. Connecticut law does not recognize the de minimis doctrine. The federal regulation implementing the Fair Labor Standards Act, 29 C.F.R. § 785.47, permits employers to disregard brief and administratively unrecordable periods of work. The Connecticut Supreme Court found no Connecticut statute, regulation, or precedent that incorporates that doctrine. Because state law already defines compensable time broadly and requires pay for time employees are required to wait on premises, the Court refused to graft a federal administrative exception onto state wage statutes.

The net result: Connecticut employers must pay employees for any employer-required time spent on premises, including short post-shift security screenings, and they cannot avoid liability by labeling such time “de minimis” simply because it is brief.

The Statutory Foundation: How Connecticut Defines “Hours Worked”

The Court’s interpretation turned on two statutory provisions that together frame Connecticut’s wage requirements.

• Conn. Gen. Stat. § 31-71b establishes that wages must be paid based on the number of hours worked.
• Conn. Gen. Stat. § 31-76b(2)(A) defines “hours worked” as “all time during which an employee is required by the employer to be on the employer’s premises or to be on duty, or to be at the prescribed workplace, and all time during which an employee is employed or permitted to work, whether or not required to do so…. Such time includes, but shall not be limited to, the time when an employee is required to wait on the premises while no work is provided by the employer.”

Two features of the statutory definition are decisive. First, it is expansive: “all time” and “includes, but shall not be limited to” signals broad coverage. Second, the statute expressly contemplates and covers waiting time on the employer’s premises. The Court read those phrases to mean that any time an employer compels an employee to remain on-site and undergo screening (or other employer-required tasks) is compensable, regardless of duration.

The statutory language contrasts with bodies of law that permit narrow exceptions when the time involved is de minimis or when practical payroll recording is impossible. Connecticut’s statute sets the baseline: if the employer requires it, it is hours worked.

The De Minimis Doctrine: Federal Origins and Connecticut’s Rejection

At the federal level, the de minimis doctrine—most clearly articulated in 29 C.F.R. § 785.47—allows employers in certain circumstances to disregard “insubstantial or insignificant periods of time beyond the scheduled working hours” that cannot be practically recorded for payroll purposes. The rule emerged from federal wage-and-hour administrative interpretations and judicial decisions interpreting the Fair Labor Standards Act (FLSA). Courts have sometimes applied the doctrine to minor activities such as brief clothing adjustments, a few minutes of equipment checks, or short pre-shift setup tasks when precise recording would be impractical and the time involved negligible.

The Connecticut Supreme Court considered and rejected the idea that that federal regulatory approach should be imported into Connecticut wage law. The Court emphasized that there is no Connecticut statute, regulation, or precedent explicitly recognizing a de minimis rule. Where the statute expressly defines compensable time as all time required on premises, adding a judicially created exception borrowed from a federal administrative regulation would effectively override legislative text. The Court declined to do that.

The Court also identified the practical implications: allowing an exception in Connecticut would create an opening for employers to avoid paying for time they require, simply because it is short or awkward to record. The availability of electronic timekeeping systems that track short intervals with precision undercut any administrative burden rationale, the Court noted. The practical upshot is clear: under Connecticut law, duration alone does not determine compensability.

How This Ruling Differs from Federal Practice and Other Jurisdictions

The federal approach and state approaches sometimes diverge. Under the FLSA and its implementing regulations, federal agencies and some federal courts permit a de minimis exception in narrowly defined circumstances, particularly when the time in question is sporadic, brief, and administratively difficult to record. That doctrine developed within the federal administrative enforcement framework and has been applied selectively by courts interpreting federal law.

States exercise authority over their own wage statutes and can adopt broader or narrower standards. Connecticut’s Supreme Court has now made clear that its statutory language requires a broader rule—any employer-required time on premises counts as hours worked. Employers operating across multiple states must therefore apply the most protective standard of the controlling jurisdiction when determining pay practices and compliance.

For employers who rely on brief unpaid security screenings, bag checks, locker checks, brief workstation cleanup, or other short end-of-shift tasks, the difference matters. Under some federal interpretations or in other states that recognize de minimis, moments of unpaid work could be defensible under narrow conditions. In Connecticut, they are not.

Practical Scenarios: What Time Must Be Paid Under Del Rio?

The ruling applies to a range of common workplace activities whenever the employer requires the employee to remain on the premises or otherwise be “on duty.” Real-world scenarios include, but are not limited to:

• Post-shift security screenings at warehouse exits. If workers must pass through metal detectors, bag checks, or electronic scanners after their scheduled shift, time spent in line or undergoing the check is compensable.
• Pre-shift security checks. Where employees must enter a secured facility and pass screening before clocking in, that pre-shift wait and screening time will be compensable.
• Required donning and doffing of employer-mandated protective clothing or equipment on the employer’s premises when the employer requires it.
• Brief end-of-shift workstation cleanup or pallet returns required by the employer after clock-out.
• Waiting in a mandatory debrief or mandatory post-shift meetings conducted after the scheduled shift.
• Employer-imposed locker searches or personal-item inspections held before employees leave the premises.
• Time spent to properly complete employer-required electronic logs or check-out processes after the shift ends, when completion is required and controlled by the employer.

To determine compensability, ask: was the employee required by the employer to remain on-site or to perform the task? If yes, Del Rio’s logic treats that time as hours worked and thus payable.

The ruling leaves room for different results where the employee voluntarily stays on premises or checks out early to attend to personal business. Voluntariness and employer control are core factors in distinguishing compensable time from voluntary, off-duty time. If an employee leaves the premises and then is subject to a screening they volunteered to undergo, the analysis could differ. But where the employer requires presence or action, Connecticut law favors compensation.

The Scale of Exposure: How Small Periods Add Up

A few seconds can accumulate into significant wage liability across a workforce and over time. Consider a hypothetical example to illustrate how seemingly trivial periods can scale:

• A warehouse employs 1,000 workers who each experience a mandatory post-shift screening averaging 90 seconds per shift.
• At $16 per hour, 90 seconds equals $0.40 per shift.
• Over a five-day workweek, that equals $2.00 per employee. Over 52 weeks, $104 per employee per year.
• Multiply by 1,000 employees and the employer’s annual wage exposure is $104,000, before interest, penalties, and litigation costs are considered.

If screening times peak at several minutes or vary substantially—e.g., up to 20 minutes when employees carry personal items—liability magnifies quickly. Class actions amplify the risk, as plaintiffs can pursue company-wide relief. Employers that have not paid for such time face both back pay exposure and the costs of litigation and potential statutory penalties.

Operational Impacts: Timekeeping, Policies, and On-Site Procedures

Del Rio shifts the compliance landscape from a practical and operational perspective. Employers must re-evaluate how they measure, record, and pay for work-related activities. The decision touches on several operational areas:

1. Timekeeping system capabilities. Employers relying on manual or coarse-grained systems that round time in large increments should consider systems that capture short increments and support audit trails. Electronic punching, biometric readers, or scanner logs can record brief intervals accurately and reduce disputes.
2. Policy clarity and communication. Employer handbooks and policies should explicitly state how pre- and post-shift activities are treated. Clear, written policies reduce ambiguity and provide expectations for workers, but they do not override statutory obligations; a policy cannot lawfully designate employer-required time as unpaid.
3. Scheduling and workstation flow. Employers can redesign arrival and departure procedures to minimize required on-premises waiting. Staggered shift ends, multiple screening stations, or enhanced throughput can reduce aggregated time spent waiting.
4. Screening design and location. If screenings must occur, positioning them so that required screening happens before the end of a scheduled shift—or ensuring employees are paid to be present during screening—avoids unpaid off-the-clock work.
5. Training and supervisor practice. Supervisors should be trained to avoid implicitly requiring employees to remain on-site after clock-out and to ensure that any required post-shift tasks are recorded and paid.
6. Use of voluntary alternatives. Where appropriate, employers may offer voluntary off-premises screening alternatives. If an employee elects a voluntary option that does not require them to remain on company property, the time may not be compensable. However, the voluntariness must be genuine and documented.
7. Record retention and audits. Maintain detailed records of time, screening logs, and policies. Regular internal audits can identify gaps and correct pay practices before claims arise.

Litigation and Class-Action Risk: Why Employers Should Take Notice

Del Rio provides plaintiffs’ counsel a clear predicate for wage-and-hour claims in Connecticut. Class actions are particularly attractive in settings where standardized employer practices apply uniformly across a workforce—warehouses, manufacturing plants, distribution centers, retail operations, and healthcare facilities.

Key litigation drivers include:

• Standardized procedures. When an employer imposes the same screening requirement across many employees and shifts, a class action focusing on company-wide unpaid minutes becomes viable.
• Electronic evidence. Timekeeping systems and screening logs that reveal unpaid post-shift waiting time can be powerful evidence for plaintiffs. The Court’s rejection of the de minimis doctrine removes a common defense.
• Statutory remedies. State wage laws typically permit recovery of unpaid wages and may include interest, liquidated damages, civil penalties, and attorney’s fees; the exact remedies vary by statute and court interpretation.
• Notice and public perception. High-profile employers with public-facing reputations can face reputational harm as well as financial exposure.

Employers should treat wage-and-hour exposure proactively. Early audits, retroactive pay analyses, and corrective pay programs can reduce the prospect and cost of litigation. When claims do arise, cooperating with regulators, promptly addressing identified violations, and engaging experienced labor counsel can limit exposure.

Steps Employers Should Take Now: A Practical Compliance Roadmap

The Del Rio ruling requires action. The following roadmap gives employers a prioritized list of steps to reduce risk and ensure compliance with Connecticut wage laws.

1. Conduct a targeted audit. Identify all activities that require employees to be on-premises outside scheduled hours—security screenings, locker checks, donning and doffing, mandatory end-of-shift tasks. Quantify typical durations and variance.
2. Review timekeeping practices. Assess whether current systems can record the brief intervals at issue. Consider upgrades to systems that capture seconds or minutes and provide immutable audit logs.
3. Reclassify and update pay practices. Where audits reveal unpaid compensable time, implement pay practices that ensure employees are remunerated for time spent in employer-required activities, including pre- and post-shift screenings.
4. Implement immediate corrective payments where necessary. If past underpayments are identified, weigh voluntary corrective payment programs and settlement discussions to reduce litigation risk and statutory exposure.
5. Update written policies and training materials. Communicate clearly that employer-required on-premises time is paid, and train supervisors and HR personnel to record and report such time accurately.
6. Redesign operational flows to minimize waiting. Wherever feasible, reconfigure screenings to occur before scheduled clock-out or reduce bottlenecks through additional screening stations and staggered exit procedures.
7. Document voluntariness where appropriate. If employees can elect to undergo screenings off-site or at different times, record that choice. Genuine, documented voluntariness provides a stronger defense.
8. Engage counsel to review exposure and mitigation. Labor and employment counsel can advise on regulatory compliance, potential retroactive liability, and settlement strategies.
9. Monitor legislative and regulatory developments. The Del Rio decision interprets Connecticut law as it stands. Future statutes or regulations could modify the legal landscape; employers should remain alert.

Examples and Illustrations: How Employers Might Apply the Ruling

Example 1: A manufacturing plant requires employees to return tools and undergo brief locker checks after their shift. Historically, the company told employees to clock out before the check. After Del Rio, the company must record and pay the time spent on such checks because employees are required to remain on-site and perform employer-directed activities.

Example 2: A retail store has a single exit station at closing where security staff scans shopping bags as employees leave. The store schedules staff to remain at the register and undertake closing tasks after the scheduled shift. Unless employees voluntarily choose to stay, the time taken to pass through the security check and complete the closing tasks is compensable.

Example 3: A hospital requires nurses to change out of scrubs at the end of a shift. The employees are required to don and doff protective clothing in a locker room on hospital premises. Time spent on donning and doffing as required by the employer is compensable under the Del Rio rationale.

Example 4: A warehouse offers employees the option to sign up for a shuttle that departs ten minutes after shift end to transport them off-site. If an employee voluntarily chooses to take the shuttle, and there is no employer requirement to wait for the shuttle, time spent waiting for the shuttle may not be compensable. Documentation of voluntary choice and lack of employer compulsion is crucial.

These scenarios underscore that the key determinants are employer requirement and control, not the absolute duration of the activity.

Employee Perspective: What Workers Should Know and Do

Workers in Connecticut should understand that Del Rio strengthens their right to be paid for employer-required time. Practical implications for employees include:

• Track time carefully. Keep contemporaneous records of arrival and departure times, any waiting time for screenings, and other required on-premises activities.
• Ask for clarification. Request written confirmation from employers about whether pre- or post-shift activities are considered paid work.
• Report suspected nonpayment. Employees who believe they have not been paid for required on-premises time can contact the Connecticut labor department or seek advice from an employment attorney.
• Preserve evidence. Retain pay stubs, schedules, timekeeping receipts, written policies, and communications that relate to unpaid time.

Clear documentation and early inquiry can resolve many disputes without litigation. Where disputes persist, employees have causes of action under Connecticut wage statutes and may pursue class claims where company-wide practices denied pay.

Broader Implications: Technology, Surveillance, and Labor Practices

The Del Rio decision interacts with two broader workplace trends: the rise of electronic timekeeping and the expansion of workplace security and surveillance. Employers increasingly use precise electronic systems and biometrics that can capture even seconds of activity. Those systems remove a prior administrative justification for ignoring small amounts of time. At the same time, security practices—bag checks, scanners, and exit monitoring—have become more common across sectors, driven by theft prevention and workplace safety concerns.

Those converging trends mean two predictable outcomes:

• Employers will be under pressure to either modify security procedures to avoid unpaid required waiting or to pay for that time.
• Employees will have more robust evidence—time stamps, logs, scanner data—to substantiate claims about unpaid minutes.

The decision also invites employers to balance security needs against labor costs. Where security is essential, employers must budget for the time cost. Where security measures can be reconfigured to reduce required employee waiting, redesign can limit exposure.

Potential Legislative and Regulatory Responses

Because the Connecticut Supreme Court based its ruling on existing statutory text and the absence of a state-level de minimis exception, the legislature or state regulators could choose to act if policymakers believe an alternative approach is appropriate. Possible responses include:

• Legislative amendment that narrows or clarifies the definition of compensable time, perhaps specifying an exception analogous to the federal de minimis standard.
• Administrative regulations under Connecticut wage law that define narrow categories of noncompensable small-time increments.
• Guidance from the Connecticut Department of Labor clarifying application of the decision to common workplace scenarios.

Until such changes occur, employers must comply with the Court’s construction of the statutes.

How This Decision Affects Multi-State Employers

Employers operating in several states must apply the wage-and-hour law of the state that governs the employment relationship. When Connecticut employees are involved, Connecticut’s approach controls. Multi-state employers should adopt the most protective practices required by any state in which they operate, or implement state-specific policies to avoid conflicting legal obligations.

A uniform approach—paying for employer-required on-premises activities across the organization—simplifies administration and reduces the risk of selective noncompliance. Even where federal de minimis doctrine might have provided a defense, it is not available in Connecticut under the current ruling.

Enforcement Landscape: Agency Action and Private Litigation

Del Rio does not only empower private litigants. Wage-and-hour violations can also attract administrative enforcement by state labor agencies. The Connecticut Department of Labor enforces state wage laws and investigates complaints. Employers that voluntarily correct underpayments and cooperate with inspections can sometimes avoid harsher penalties, but this varies by the facts.

Private litigation remains a primary enforcement mechanism. Typical remedies sought in wage claims include unpaid wages, interest, and in some states statutory penalties and attorney’s fees. Class actions are particularly effective when employer practices are centralized and uniform.

Employers should consider early remediation programs that identify underpayments, calculate back wages, and offer corrective payments to affected workers, combined with procedural steps to limit litigation exposure.

Practical Draft Policies: Sample Language Employers Can Use

Employers should consult counsel for tailored policy language. The following sample clauses show the type of clarity courts and regulators expect; they do not substitute for legal advice.

• “All time during which employees are required to wait on the employer’s premises or to be on duty, including pre- and post-shift security screenings, is compensable time and must be recorded in the timekeeping system.”
• “Employees who are required to undergo employer-directed security screenings will be paid for the time spent waiting for and completing those screenings. Do not leave the premises before completing required timekeeping procedures unless otherwise authorized by a supervisor.”

Policies must be enforced consistently. A policy stating that screening time is unpaid will not shield an employer from liability if employees are required to remain and perform those tasks.

When Employers May Lawfully Avoid Payment

There are limited scenarios where screening time may not be compensable under the Court’s analysis:

• Genuine voluntariness. If an employee elects to remain on the premises for personal reasons and the employer does not require the presence, that time may not be compensable.
• Off-premises screening. If an employee leaves company premises and is later subject to a screening that is not required by the employer, payability may differ.
• Non-employer controlled security. If an outside entity—unrelated to workplace policies—performs screenings and the employee is not subject to employer direction, the analysis could change.

Those scenarios are fact-specific and require careful documentation.

Steps for Employees Seeking Redress

Employees who believe they were not paid for required screening time should take these steps:

• Collect and preserve evidence: paystubs, schedules, time logs, photographs, and any written policies.
• Keep a contemporaneous log of instances where screening occurred and the time it consumed.
• Check internal complaint processes: file a formal complaint with HR and request written acknowledgement.
• Contact the Connecticut Department of Labor for guidance on filing a wage claim.
• Consult an employment attorney, particularly if the issue affects many shifts or there is resistance from the employer.

Prompt steps and documentation increase the likelihood of a favorable resolution.

Anticipating Employer Arguments Post-Del Rio

After Del Rio, employers may still raise several defenses; their viability will depend on the facts and documentation.

• Administrative impracticability. Employers may argue that recording short times is administratively impractical, but Del Rio undermines that defense in Connecticut, especially where electronic systems can capture brief intervals.
• De minimis. This explicit defense is unavailable under Connecticut law after Del Rio.
• Voluntariness. If the employee voluntarily remained on premises or to undergo screening, the employer may not owe pay. Proof of voluntariness is key.
• Lack of control. Employers may contend they did not require the time. Courts will analyze employer policies, supervisor directives, and practice.

The strongest defenses are grounded in documented voluntariness or lack of employer compulsion; otherwise, payment is likely required.

Cost-Benefit Considerations: Paying for Minutes vs. Redesigning Procedures

Employers face a choice: pay for the required minutes or redesign processes to eliminate required on-site time. The right choice depends on business needs and cost analysis.

• Paying may be simplest where the cost of compensation is less than the expense of operational redesign.
• Redesign may be optimal where security requirements can be met through pre-shift procedures, staggered exits, increased screening capacity, or off-site alternatives that do not place the employer in control of the employee while unpaid.
• Hybrid approaches—reducing peak congestion while compensating for unavoidable waiting—often yield balanced outcomes.

Financial modeling should include the likely wage exposure, potential retroactive liability, legal defense costs, and the operational expense of redesign.

Looking Ahead: Employer Practices Likely to Change

Following Del Rio, expect employers—especially those that operate large facilities with security screening—to take several actions:

• Invest in better timekeeping systems that capture brief events with enforceable audit trails.
• Re-evaluate exit and entry procedures to minimize required on-site waiting or to integrate screening into paid time.
• Offer voluntary off-site screening options with documented consent.
• Implement compliance audits and corrective pay programs where past underpayments are discovered.
• Increase training for managers and HR teams about recording and paying for short-duration, employer-required tasks.

These changes will reduce exposure to wage claims and ensure alignment with Connecticut’s statutory requirements.

FAQ

Q: Does Del Rio mean every second on the employer’s premises must be paid? A: No. Del Rio establishes that time required by the employer while the employee is on the employer’s premises or on duty is compensable. Time that is genuinely voluntary or outside employer control may not be compensable. The ruling removes a broad de minimis exception based solely on duration.

Q: How does this decision interact with federal law? A: Federal law and regulations (notably 29 C.F.R. § 785.47) permit a narrow de minimis exception in certain circumstances under the FLSA. Connecticut law is interpreted independently; this decision denies the adoption of that federal administrative exception into Connecticut wage statutes.

Q: Does Del Rio only apply to Amazon or to all Connecticut employers? A: The Court’s interpretation of Connecticut statutes applies statewide and is not limited to Amazon. Any Connecticut employer that requires employees to remain on the premises for screenings, checks, or employer-directed tasks must pay for that time.

Q: If an employer upgrades timekeeping, can it avoid liability for past unpaid minutes? A: Upgrading timekeeping helps prevent future noncompliance but does not erase past underpayments. Employers that identify past unpaid compensable time should evaluate corrective payment programs and consult counsel to address retroactive liability.

Q: Are penalties or interest available for unpaid wages under Connecticut law? A: Remedies for unpaid wages can include back pay and other statutory relief under Connecticut law. The precise range of penalties, interest, and attorney fee awards depends on statutory provisions and case-specific facts. Employers should consult counsel about remediation strategies.

Q: What should supervisors be trained to do after this decision? A: Supervisors should be trained to record all employer-required time accurately, avoid instructing employees to remain on-site without payment, document any voluntary off-premises options chosen by employees, and ensure consistent application of pay policies.

Q: Can employers make screenings voluntary to avoid paying? A: Employers can consider voluntary options, but voluntariness must be genuine and documented. Employers should avoid creating circumstances that effectively coerce employees to remain on premises for unpaid screenings.

Q: Could Connecticut’s legislature adopt a de minimis rule in response? A: Yes. Legislatures can amend statutes or adopt regulations to change legal frameworks. Until any such legislative or regulatory change occurs, employers must follow the Connecticut Supreme Court’s ruling.

Q: What immediate compliance steps should Connecticut employers take? A: Conduct a targeted audit of required pre- and post-shift activities, update timekeeping systems and policies, pay for identified compensable time going forward, consider corrective payments for past unpaid hours, and consult employment counsel.

Q: How should employees document unpaid screening time? A: Keep contemporaneous logs noting shift times, screening start and end times, witness names, and any communication about screenings. Preserve paystubs, policies, and any electronic logs or scanner timestamps that corroborate time records.

Del Rio v. Amazon reframes a familiar reality: minutes, when required by an employer, are wages. Connecticut’s highest court replaced a pragmatic administrative exemption with a statutory fidelity that favors compensation for employer-controlled time. For employers, the message is operational: redesign procedures where feasible, pay where necessary, and record everything accurately. For workers, the decision strengthens the right to compensation for time the employer requires. The legal, financial, and operational consequences will continue to unfold as businesses adjust their practices and as the state’s enforcement and litigation landscape responds.