Connecticut “On-Premises Means Paid”: Mandatory Security Screening Time Is Compensable and No De Minimis Exception Applies

I. Introduction

Case: Del Rio v. Amazon.com Services, Inc.
Court: Supreme Court of Connecticut
Officially released: February 10, 2026
Posture: Certified questions from the United States Court of Appeals for the Second Circuit under § 51-199b (d).

This putative class action was brought by three Amazon warehouse employees—Javier Del Rio, Colin Meunier, and Aaron Delaroche—on behalf of themselves and similarly situated employees. They alleged that Amazon violated Connecticut wage laws by failing to pay for time spent undergoing mandatory anti-theft security screenings on Amazon’s premises at the end of shifts.

Amazon obtained summary judgment in federal district court based largely on federal wage-and-hour doctrine, particularly Integrity Staffing Solutions, Inc. v. Busk, which held that such screening time is not compensable under the federal Fair Labor Standards Act (FLSA) as amended by the Portal-to-Portal Act (PTPA). On appeal, the Second Circuit certified two questions to the Connecticut Supreme Court:

  1. Under Connecticut wage laws and regulations, must employees be compensated for time spent going through mandatory security screenings at their place of employment?
  2. Does a de minimis exception apply, and if so, what factors govern it?

The Connecticut Supreme Court answered: (1) yes, and (2) no—there is no de minimis exception under Connecticut law in this context.

II. Summary of the Opinion

The Court held that Connecticut’s wage laws are more protective than federal wage laws as to mandatory on-premises security screenings. Under the plain and unambiguous text of General Statutes § 31-76b (2) (A), “hours worked” include “all time during which an employee is required by the employer to be on the employer’s premises,” including time spent waiting while “no work is provided.”

Because Amazon required employees to remain on-site to complete the screening process before exiting, that time is compensable under Connecticut law. The Court further held that Connecticut law does not incorporate the federal de minimis doctrine—neither by statute, regulation (including the state’s 15-minute rounding rule), nor binding precedent.

III. Analysis

A. Precedents Cited

1. The federal baseline and the “floor-not-ceiling” framework

The Court situated the dispute within the relationship between federal and state wage laws. Citing Sarrazin v. Coastal, Inc., it reiterated that the FLSA sets “a national floor” and that states may provide equal or greater worker protection without preemption. This framing mattered because Amazon’s central argument was “coextensiveness”: that Connecticut intended to track federal limits (including PTPA exclusions and federal doctrines like de minimis).

2. Federal “work” doctrine and the Portal-to-Portal Act line

The opinion reviewed the federal arc from expansive judicial definitions of “work” to Congress’ narrowing response:

  • Tennessee Coal, Iron & Railroad Co. v. Muscoda Local No. 123: defined “work” broadly as exertion controlled or required by the employer and pursued for the employer’s benefit.
  • Armour & Co. v. Wantock: expanded compensable time to include “readiness to serve,” including paid waiting time when the employer hires someone “to do nothing but wait.”
  • Anderson v. Mt. Clemens Pottery Co.: defined “workweek” broadly and catalyzed litigation over walking/waiting time.
  • The PTPA then excluded certain “preliminary” and “postliminary” activities.
  • Integrity Staffing Solutions, Inc. v. Busk: held that time spent in mandatory security screenings is a noncompensable postliminary activity under the FLSA/PTPA because it is not “integral and indispensable” to warehouse workers’ principal activities.

The Connecticut Supreme Court treated this federal history as context, but ultimately as non-controlling because Connecticut’s statutory definition of “hours worked” is textually broader and differently structured.

3. Connecticut interpretive method: textualism under § 1-2z

The Court emphasized that Connecticut statutory interpretation begins (and often ends) with text under § 1-2z, citing Health Body World Supply, Inc. v. Wang and related interpretive cases. It also relied on:

  • State v. Crespo (clarifying that a statute may be clear in one context but ambiguous in another),
  • State v. Panek (legislature may define terms differently than dictionaries),
  • Efstathiadis v. Holder (harmonizing related statutes),
  • Ledyard v. WMS Gaming, Inc. (using contemporaneous dictionaries for undefined terms),
  • State v. Moore, Rivers v. New Britain, and PPC Realty, LLC v. Hartford (the “absurd or unworkable results” safety valve is “strong medicine” to be used sparingly),
  • Doe v. Norwich Roman Catholic Diocesan Corp. and Tuxis Ohr's Fuel, Inc. v. Administrator, Unemployment Compensation Act (courts cannot rewrite statutes; adding exceptions is for the legislature/regulator).

4. Belgada and why it did not control

Amazon relied heavily on Belgada v. Hy's Livery Service, Inc., where the Appellate Court found ambiguity in the word “work” when analyzing whether meal breaks were compensable (because the statute excludes meal time unless the employee is required or permitted to work).

The Supreme Court distinguished Belgada as a different statutory clause and context: the present case turned on the “on the employer’s premises” clause, not the meal-break “required or permitted to work” clause. Thus, the undefined word “work” was not dispositive because § 31-76b (2) (A) expressly includes time on premises even when “no work is provided.”

5. De minimis and rounding: federal doctrine vs. Connecticut’s scheme

The Court reviewed the federal de minimis doctrine (rooted in Anderson v. Mt. Clemens Pottery Co. and reflected in 29 C.F.R. § 785.47) and noted federal factors articulated in Singh v. New York. It also discussed rounding (29 C.F.R. § 785.48), and referenced rounding litigation and rationale via Aguilar v. Management & Training Corp. and See's Candy Shops, Inc. v. Superior Court.

But the Court held that Connecticut’s regulatory 15-minute computation rules—Regs., Conn. State Agencies § 31-60-11 (a) (working time “computed to the nearest unit of fifteen minutes”) and § 31-60-12 (a) (4) (records computed to nearest 15 minutes)—do not imply a de minimis exception. Rounding is a method intended to fully compensate over time, not an authorization to disregard small amounts of compensable time.

6. Sarrazin and Nettleton: not an adoption of de minimis

Amazon argued that Sarrazin v. Coastal, Inc. recognized de minimis (pointing to footnote 16). The Court rejected this: the discussion in Sarrazin addressed the federal “national floor” under the FLSA/PTPA, not Connecticut’s independent statutory scheme.

Amazon also relied on Nettleton v. C & L Diners, LLC, where the Appellate Court discussed a de minimis defense in an E4 claim context. The Supreme Court held Nettleton did not decide the question whether Connecticut wage law generally incorporates a federal de minimis exception because the issue was not presented or analyzed; the Appellate Court proceeded on an assumption rather than a considered holding. In support of this limited-precedent principle, the Court cited State v. DellaCamera, Dept. of Public Safety v. Freedom of Information Commission, and analogized to Clark v. Waterford, Cohanzie Fire Dept..

7. Certification scope and factual disputes

The opinion also policed the boundary between the certified legal question and factual disputes, citing Capstone Building Corp. v. American Motorists Ins. Co. and In re Amazon.com, Inc. This was relevant to Amazon’s argument that some screening time was “optional” due to employee choice (e.g., bringing bags). The Court declined to resolve those factual questions because the certification assumed “mandatory security screenings” as framed.

B. Legal Reasoning

1. The rule comes from the statutory text: “all time … required … to be on the employer’s premises”

The Court’s core move is a straightforward application of § 1-2z to the definition in § 31-76b (2) (A). The statute defines “hours worked” to include:

  • all time during which an employee is required by the employer to be on the employer’s premises,
  • and expressly includes waiting time on premises even when no work is provided.

On undisputed facts, Amazon required employees to remain on the premises until they completed screening and were allowed to leave. That “on-premises requirement” satisfied the statute, making the time compensable without any need to import federal PTPA concepts (principal activities; integral and indispensable).

2. Rejecting “ambiguity” attempts that would reopen legislative history

Amazon attempted to manufacture ambiguity by focusing on the undefined word “work” and by arguing that wage statutes compensate only “labor or services.” The Court rejected both:

  • “Work” is not the operative term for the on-premises prong; the phrase “hours worked” is defined and includes time when “no work is provided.”
  • Even under the “labor or services” definition of wages, being required to remain on premises at the employer’s command can constitute a “service” (using dictionary definitions).

3. Absurd or unworkable results: high bar not met

The Court refused to treat recordkeeping inconvenience as “absurd or unworkable,” emphasizing that this doctrine is exceptional. The Court noted a practical solution (placing time clocks outside the screening area). It also rejected hypothetical employer-control concerns (employees taking elevators, circuitous routes) as policy arguments better addressed by the legislature and as insufficient to override plain statutory text, citing Adesokan v. Bloomfield and Trinity Christian School v. Commission on Human Rights & Opportunities.

4. No de minimis exception: silence is decisive given the structure and the “all time” command

The Court’s de minimis holding rests on three related points:

  • No textual hook: Connecticut statutes and wage regulations do not contain a de minimis carve-out for otherwise compensable “hours worked.”
  • Rounding is not de minimis: The 15-minute computation rule is a timekeeping convention aimed at accurate compensation overall, not a permission to disregard compensable time.
  • Institutional competence/policy: Creating a de minimis exception would be a policy choice for the legislature or Department of Labor, not a judicially crafted limitation, particularly in a heavily regulated area.

C. Impact

1. Immediate practical consequences for employers

Connecticut employers who require end-of-shift screenings (or comparable controlled exit procedures) should treat this decision as requiring compensation for that time if the employee must remain on the premises. This may require operational changes such as:

  • moving punch-out locations to after the screening area,
  • revising timekeeping and payroll rounding practices to ensure employees are paid for the screening period,
  • auditing other “required on-premises but not productive” time (e.g., mandatory lines, controlled exits, or other employer-imposed detention on premises).

2. Litigation and class/collective claim exposure

Because the rule is categorical and text-based, it is likely to increase the viability of wage claims (including class actions) where employers require employees to remain on-site post-shift. The Court’s rejection of a de minimis doctrine removes a common defense for small-per-employee time amounts that can become substantial in the aggregate.

3. Doctrinal significance: Connecticut decouples from federal Portal-to-Portal limits for “on premises” time

The most important doctrinal development is the Court’s clear separation between:

  • federal FLSA/PTPA “principal activity / integral and indispensable” analysis, and
  • Connecticut’s “required to be on the employer’s premises” statutory definition of compensable time.

This decision therefore signals that, even where Connecticut courts consult federal law for guidance in some wage contexts, federal limits cannot override Connecticut’s explicit statutory text when the state statute is broader.

4. Open questions left for future cases

The decision intentionally leaves factual and application issues for later litigation, including:

  • whether certain screening lanes are truly “required” or effectively optional (the Court declined to resolve that factual dispute),
  • how Connecticut’s 15-minute rounding rule must be implemented to ensure employees are “fully” compensated in practice,
  • how the rule interacts with meal-break screening (the Court did not reach the meal-break clause issue).

IV. Complex Concepts Simplified

  • “Hours worked” (Connecticut): Under § 31-76b (2) (A), it includes all time your employer requires you to be on the employer’s premises—even if you are waiting and not performing tasks.
  • Portal-to-Portal Act (federal): A federal amendment that excludes certain before/after shift activities from pay, unless they are “integral and indispensable” to the main job.
  • “Integral and indispensable” (federal): An activity that is a necessary, intrinsic part of the employee’s principal work. Under Integrity Staffing Solutions, Inc. v. Busk, security screenings were not.
  • De minimis doctrine (federal): A rule allowing employers to ignore tiny amounts of time when they are administratively hard to record. Connecticut, in this decision, declined to recognize that doctrine.
  • Rounding rule: A timekeeping method that rounds clock-in/out times to set increments (Connecticut: 15 minutes by regulation). Rounding is not the same as refusing to pay; it is supposed to balance out so employees are paid for all time over time.
  • Certified question: A federal court asking a state supreme court to decide unsettled questions of state law, ensuring the state’s highest court gives an authoritative interpretation.
  • “Absurd or unworkable results” doctrine: A narrow exception allowing courts to avoid a literal reading only when the outcome would be obviously bizarre or impossible to administer. The Court held paying for mandatory screening time does not meet that standard.

V. Conclusion

Del Rio v. Amazon.com Services, Inc. establishes a clear Connecticut rule: when an employer requires employees to remain on the employer’s premises to undergo mandatory security screenings at the end of a shift, that time is compensable as “hours worked” under § 31-76b (2) (A). The Court simultaneously rejected importing the federal de minimis doctrine into Connecticut wage law, emphasizing that neither the statutes nor the regulations create such an exception and that crafting one would be a legislative or regulatory—not judicial—choice.

The decision is significant for Connecticut wage-and-hour law because it anchors compensability in the statute’s “required to be on the employer’s premises” text rather than in federal Portal-to-Portal concepts, thereby expanding employee protection beyond the federal baseline in a concrete and operationally consequential setting.