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California de Minimus Doctrine and Your off the Clock Wages

A recent verdict in Troester v. Starbucks Corporation ignited a shift in off-the-clock wages.

Douglas Troester, a manager at a Starbucks coffee store in California, claimed that the corporation failed to compensate him for the time he spent completing miniscule tasks related to his position. Each shift, over 17 months of employment, he claimed Starbucks required him to clock out and still complete various necessary business requirements.

In his evidence, he alleged that the “close store procedure” included transmitting daily sales to larger corporate locations, activating the alarm and locking the front door. He also alleged that Starbucks policy included taking responsibility for his Starbucks associates, and he upheld his role as manager by walking individual employees safely to their vehicles.

California wages: The de minimus rule

After appeals and hearings, the Supreme Court considered the “de minimus rule” under federal law in Troester’s case. The de minimus rule states that employers may disregard a payment to employees for “infrequent and insignificant” periods of time spent beyond scheduled hours. Troester claimed that he only spent approximately 10 minutes per shift completing closing activities, yet these minutes added up quickly.

Starbucks Corporation alleged that his small amount of unpaid time was minimal under the de minimus rule, as his minutes spent off the clock did not require compensation.

After appeals, the Ninth circuit asked the Supreme Court to determine whether the de minimus doctrine held true under specific sections of California Labor Law.

The verdict came with a corporate impact

The Supreme Court ruled that under California law, businesses must pay workers for tasks that prove significant and regular. Because Troester claimed that the corporation refused to compensate him for 10 minutes per shift for nearly a year and a half, the Ninth Circuit must now apply the Supreme Court’s decision to Troester’s case.

The significance of the verdict lies heavily in corporate environments. Thousands of employees, across the United States, work minutes off the lock to open businesses and close shops. Especially for companies as large as Starbucks Corporation, California’s Ninth Circuit decision on de minimus rule wages impacts individual employees throughout the country.

Perhaps this ruling indicates a shift in off-the-clock employees’ earnings, and California court may see an upswing in lawsuits centralized on missing earnings.

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