Steiner v. Mitchell

Citations: 100 L. Ed. 2d 267; 76 S. Ct. 330; 350 U.S. 247; 1956 U.S. LEXIS 1743Docket: 22

Court: Supreme Court of the United States; January 30, 1956; Federal Supreme Court; Federal Appellate Court

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The case concerns the application of the Fair Labor Standards Act (FLSA) and the Portal-to-Portal Act regarding whether workers at a battery plant must be compensated for time spent changing clothes and showering before and after their shifts, given the hazardous materials they handle. The Secretary of Labor argues that these activities are integral to the employees' principal work of battery production and thus should be compensable. The District Court ruled in favor of the Secretary, a decision affirmed by the Court of Appeals, emphasizing the necessity of these activities for health and hygiene due to the toxic substances involved. The Supreme Court granted certiorari to address the conflict in circuit interpretations of the Portal-to-Portal provisions. The case does not involve back pay claims, as the judgment is limited to prospective relief, and it is acknowledged that under normal circumstances, changing clothes and showering would be considered non-compensable preliminary or postliminary activities. However, the unique conditions at the plant, where lead and other toxic materials are pervasive, prompt the conclusion that these activities are essential components of the employees' work.

Abnormal lead concentrations were identified in some employees of the petitioners, prompting a recommendation from the petitioners' insurance doctor to segregate these workers from their usual duties. Lead poisoning primarily occurs through inhalation and ingestion, creating significant health risks, which extend beyond the workplace due to lead dust and fumes adhering to employees' skin, clothing, and hair. Families of battery workers also face potential exposure from contaminated clothing. Additionally, sulphuric acid poses a severe hazard, causing skin irritation and burns, and increases susceptibility to lead contamination.

To mitigate these risks, petitioners implement plant ventilation, but experts agree that this alone is insufficient. Safe operation necessitates facilities for employees to change clothes and shower, which is mandated under Tennessee law. The Tennessee Workmen's Compensation Act designates lead poisoning as a compensable occupational disease, requiring petitioners to carry insurance that mandates such hygiene facilities. 

In practice, petitioners have installed shower facilities and locker rooms and provide employees with clean but worn work clothing, as the corrosive nature of sulphuric acid renders personal work clothes impractical. Employees are required to change into work clothes before starting their shifts and to shower and change back afterward, which amounts to about thirty minutes of additional time daily. Although petitioners do not formally document or compensate this time, they acknowledge its necessity for safe and efficient operations. 

The trial court determined that these hygiene activities are essential to the employees' work, fulfill mutual obligations between the employer and employees, directly benefit the business, and are integral to the employees' principal activities. However, petitioners argue these activities occur outside the scope of "principal activity" under the Fair Labor Standards Act, as they take place off the production line and before or after regular working hours.

The court determined that the time spent on certain activities is included in coverage under Section 4 of the Portal-to-Portal Act, qualifying as "time worked" under the Fair Labor Standards Act (FLSA). The Court of Appeals upheld this view, interpreting 'principal activity or activities' in Section 42 to encompass tasks that are integral and indispensable to the principal activities. The Portal-to-Portal Act was enacted to address concerns stemming from potential unexpected liabilities as established in Anderson v. Mt. Clemens Pottery Co. The trial court's ruling is limited to services rendered after the judgment becomes final, rendering Section 2 inapplicable to actions related to employee activities after May 14, 1947.

Section 4's language is ambiguous, necessitating reference to its legislative history. Initially, the House bill did not include a provision similar to Section 4. However, the Senate's discussions clarified that activities such as changing clothes and showering could fall under the Act's protections if they are integral to employees' principal activities. While there is conflicting history from the House, the Senate's intent is deemed more definitive. The addition of Section 3(o) in 1949 suggests that while changing clothes and washing may be part of the principal activities, they can be excluded by agreement. Furthermore, Section 16(c) indicates Congress’s understanding of the scope of Section 4, allowing for compensation of preparatory activities closely related to principal activities.

Overall, Congress aimed to prevent claims prior to 1947 for wages based on employee activities unless specified by contract or industry custom, but did not intend to deny employees FLSA benefits for activities that are integral and indispensable to their principal duties. Activities occurring before or after regular work hours are compensable under the Portal-to-Portal provisions if they meet these criteria and are not explicitly excluded by Section 4(a)(1).

Changing clothes and showering are deemed integral to the principal activities of employees in this case, thus warranting compensation under the Fair Labor Standards Act (FLSA). The court affirmed the judgment, emphasizing that preparatory activities closely related to productive work, such as tool maintenance, must be compensated. A discussion among senators clarified that any worker activity deemed indispensable to the performance of primary tasks is considered part of the principal activity. Examples provided include machine maintenance before work and garment workers preparing for their tasks. The committee's position is that all time spent on these activities is compensable. Additionally, the requirement for workers in chemical plants to change clothing and showering is also acknowledged as potentially compensable under the same principle.

Mr. Cooper emphasizes the distinction between compensable and non-compensable activities under the Fair Labor Standards Act (FLSA). He states that if an employee must change into specific clothing to perform their job, the time spent doing so is compensable as part of their principal activity. Conversely, if changing clothes is merely for convenience and not essential to the work, that time is not compensable. 

Mr. Barkley presents a scenario involving a machinist required to prepare tools before starting his primary work at 8 a.m. He argues that this preparation time, which adds to the total hours worked, should be considered part of the employee's principal employment. He questions whether the 40-hour workweek requirement is met if the employee works 8.5 hours daily due to this preparation time.

Mr. Cooper references a committee report that supports compensability in such situations, asserting that activities like tool preparation are intended to be compensated as part of the principal activity. 

The excerpt also outlines Section 4 of the Act, which states that employers are not liable for failing to pay minimum wages or overtime for certain activities, specifically travel to and from work and preliminary or postliminary activities. However, if these activities are deemed compensable, the employer cannot be relieved of liability.

An employer is not liable under the Fair Labor Standards Act, Walsh-Healey Act, or Bacon-Davis Act for failing to pay minimum wages or overtime for activities conducted by an employee prior to May 14, 1947, unless those activities were compensable under either: 1) an express term of a written or nonwritten contract in effect at the time, or 2) a custom or practice in place at the employee's work location that does not conflict with any existing contract. Additionally, in calculating hours worked for wage purposes, time spent changing clothes or washing at the start or end of the workday can be excluded if such practices are specified in a bona fide collective-bargaining agreement. Regulations, interpretations, or agreements from the Wage and Hour Division or Secretary of Labor that were in effect before this Act remain valid unless they conflict with new provisions or are amended, modified, or rescinded according to the new Act.