IBP, Inc. v Alvarez
Encyclopedia
IBP, Inc. v Alvarez, a Supreme Court
case in 2005, expanded worker protections initially outlined in the Federal Labor Standards Act (FLSA) of 1938, as amended by the Portal-to-Portal Act of 1947. Workers for the Iowa Beef Processors, Inc
. (IBP, Inc.), now known as Tyson Foods, Inc., filed a class-action lawsuit requesting reparations for unpaid wages. Workers were not being paid for time spent putting on and taking off protective gear, nor for time walking to and from the changing area. IBP, Inc. argued that changing into protective gear did not constitute a “principal activity” of the job, and thus was not compensable by law.
The court moderated its opinion slightly, siding with the employer regarding time waiting in line for protective gear. This waiting time, “two steps removed from principal activities”, is not compensable under FLSA regulations. However, time spent waiting to doff protective gear before leaving at the end of the workday
is compensable. Further, compensable work hours begin at the time the employer asks employees to arrive. If employees are forced to wait at the beginning of their shift because the employer does not yet have protective gear available, employees will be compensated for their waiting time.
, First Circuit, in Tum v Barber Foods, Inc in 2003. Forty-four employees filed a class action suit against Barber Foods, Inc., identical in nature to employees' complaints against IBP, Inc. Barber Foods successfully argued that time spent donning and doffing protective gear was minimal (2–4 minutes per day) and not included in productive work activity. Thus, Barber Foods was not required to compensate employees for time spent changing, waiting or walking between the changing room and the meatpacking floor.
Supreme court
A supreme court is the highest court within the hierarchy of many legal jurisdictions. Other descriptions for such courts include court of last resort, instance court, judgment court, high court, or apex court...
case in 2005, expanded worker protections initially outlined in the Federal Labor Standards Act (FLSA) of 1938, as amended by the Portal-to-Portal Act of 1947. Workers for the Iowa Beef Processors, Inc
IBP, Inc.
IBP, Inc., formerly known as Iowa Beef Processors, Inc., now Tyson Fresh Meats, is now an American meat packing company based in Dakota Dunes, South Dakota, USA. IBP was the United States' biggest beef packer and its number two pork processor until it was acquired by Tyson Foods in 2001 for US$3.2...
. (IBP, Inc.), now known as Tyson Foods, Inc., filed a class-action lawsuit requesting reparations for unpaid wages. Workers were not being paid for time spent putting on and taking off protective gear, nor for time walking to and from the changing area. IBP, Inc. argued that changing into protective gear did not constitute a “principal activity” of the job, and thus was not compensable by law.
Court ruling
The Supreme Court ruled unanimously in the workers' favor. According to the opinion released, donning protective gear and walking to and from changing areas are “integral and indispensable” to the job's “principal activities”, and must, therefore, be compensated.The court moderated its opinion slightly, siding with the employer regarding time waiting in line for protective gear. This waiting time, “two steps removed from principal activities”, is not compensable under FLSA regulations. However, time spent waiting to doff protective gear before leaving at the end of the workday
Workday
Workday may refer to:* A day in the workweek.* Working time, the period of time an individual spends at paid occupational labor* Workday, Inc., a business software company...
is compensable. Further, compensable work hours begin at the time the employer asks employees to arrive. If employees are forced to wait at the beginning of their shift because the employer does not yet have protective gear available, employees will be compensated for their waiting time.
Implications
IBP, Inc. v Alvarez encourages employers to minimize barriers to the use of protective gear. Employers who devalue the protection of their employees by having insufficient gear, or small or distant changing areas will suffer reduced efficiency resulting from paid, unproductive work hours.History
This case overturned a previous ruling by the United States Court of AppealsUnited States court of appeals
The United States courts of appeals are the intermediate appellate courts of the United States federal court system...
, First Circuit, in Tum v Barber Foods, Inc in 2003. Forty-four employees filed a class action suit against Barber Foods, Inc., identical in nature to employees' complaints against IBP, Inc. Barber Foods successfully argued that time spent donning and doffing protective gear was minimal (2–4 minutes per day) and not included in productive work activity. Thus, Barber Foods was not required to compensate employees for time spent changing, waiting or walking between the changing room and the meatpacking floor.