On February 10, 2026, the Connecticut Supreme Court officially released its decision in Del Rio v. Amazon.com Services Inc. (SC 21109), holding that under Connecticut law, employers must compensate employees for time spent undergoing mandatory security screenings on the employer’s premises. This decision marks a notable departure from federal law, as the Fair Labor Standards Act of 1938 (“FLSA”) does not require such compensation. We provide an overview of the Court’s holding and its implications for Connecticut employers below.
The Case: Amazon’s Mandatory Post-Shift Security Screenings
This case arises from a class action lawsuit filed by Amazon employees, alleging violations of Connecticut’s wage laws for uncompensated time spent undergoing mandatory security screenings at the end of their shifts. These screenings varied from brief visual checks to more involved physical procedures, depending on items carried by the employee, and could involve walking through metal detectors, placing items in baskets for scanning, or utilizing X-ray machines for bags. If an alarm was activated during any of the screening processes, the employee then proceeded to a secondary screening with a hand-held metal detector. While typically lasting a few seconds to minutes, in some cases the screening extended up to twenty minutes.
The federal district court held that such time was not compensable, reasoning that Connecticut’s wage laws mirrored the FLSA’s, which excludes security screenings from compensation. On appeal, the United States Court of Appeals for the Second Circuit certified two questions of law to the Connecticut Supreme Court: (1) whether Connecticut’s wage laws and regulations require employees to be compensated for time spent undergoing mandatory workplace security screenings, and (2) whether a de minimis exception applies to such time and, if so, what factors govern that analysis.
Connecticut Supreme Court Finds Post-Work Screenings Compensable
The Supreme Court of Connecticut held that, under Connecticut law, employers must compensate employees for time spent undergoing mandatory workplace security screenings and that Connecticut wage laws do not incorporate a de minimis exception to compensability.
The Court focused on the plain language of Connecticut General Statutes § 31-76b(2)(A), which requires employees to be compensated for four categories of time: (1) when the employer requires the employee to be on the employer’s premises; (2) when the employee is on duty; (3) when the employer requires the employee to be at the proscribed work place; and (4) when the employee is employed or permitted to work, whether or not required to do so. The Court explained that “hours worked” under the statute means “all time during which an employee is required by the employer to be on the employer’s premises,” including “the time when an employee is required to wait on the premises while no work is provided by the employer.” The Court held that “[b]ecause it is undisputed that Amazon required the plaintiffs to remain on its premises during the mandatory security screenings, their time was compensable under the plain language of § 31-76b (2) (A).” In doing so, the Court rejected Amazon’s argument that the statute yields an absurd or unworkable result, suggesting that employers could easily track this time by relocating time clocks outside of the security screening area.
Notably, this decision contrasts with federal law, which under Integrity Staffing Solutions, Inc. v. Busk, 574 U.S. 27 (2014) treats security screenings as noncompensable “postliminary activities.” The Court also found that Connecticut wage laws do not incorporate a de minimis exception to compensability, unlike federal wage law. Under Connecticut law, employers must pay employees for “all time” that counts as “hours worked” as defined by § 31-76b (2) (A).
What This Means for Connecticut Employers
The Del Rio decision has important implications for all Connecticut employers, as it clarifies that Connecticut law requires compensation for all time an employee is required to be on-site at work. Employers should review their practices and policies to ensure compliance with Connecticut wage law, especially those in manufacturing, construction, or warehousing, where mandatory pre-or post-shift activities are common.
- Review timekeeping practices. Employers who require employees to undergo exit procedures after clocking out, such as security screenings, bag checks, or other processes, should ensure their timekeeping practices accurately capture and compensate time spent undergoing such screenings.
- No de minimis Connecticut law does not permit employers, in this context, to disregard small amounts of time spent doing mandatory post-shift activities, even where such time may be considered noncompensable under federal law. Even whenpost-shift activities take only a few minutes, Connecticut law requires compensation for that time.
- Assess overtime exposure. Employers should assess how compensating for these screenings may push certain employees into overtime, and ensure they are paying overtime as required under Connecticut law and the FLSA.
- Evaluate potential liability. Employers should assess whether prior practices could expose them to claims for unpaid wages and adjust accordingly.
Conclusion
The Del Rio decision is a significant Connecticut wage ruling, and raises compliance concerns for Connecticut employers. Although the ruling applies to all employers, those who operate warehouses or are in the construction sectors where mandatory post-shift activities are common should audit their practices immediately. Failure to properly compensate for all hours worked, even de minimis time, can lead to costly wage and hour litigation and substantial back pay awards.
Hinckley Allen’s Labor & Employment Group understands these complexities and can assist your business in proactively reviewing policies, developing strategies to mitigate risk, and if required defending against claims under Connecticut and federal wage laws. If you have questions about how this decision affects your operations, or concerns about past practices, contact your employment attorney today.