Connecticut Supreme Court Rules Amazon Must Pay Workers for Security Screening Time — What It Means for You

If you work – or used to work – at an Amazon fulfillment center in Connecticut, you may be owed money you never received. And even if you don’t work for Amazon, this ruling could affect your paycheck too.

Picture the end of your shift. The clock says it’s time to go home. But before you can walk out the door, your employer makes you stand in line and pass through a security screening – a metal detector, an X-ray machine, maybe a pat-down. That can take anywhere from a few seconds to twenty minutes. And the whole time, you’re on your employer’s property, following their rules, going nowhere until they say you can.

Were you getting paid for that time? If you worked at an Amazon warehouse in Connecticut before March 2020, the answer was almost certainly no. Amazon said it didn’t have to pay. A federal trial court agreed. But in February 2026, the Connecticut Supreme Court said something different: that time is compensable, and employers must pay for it.

If your employer requires you to stay on-site after your shift ends – for any reason – Connecticut law may require them to pay you for that time.

The Case: Del Rio v. Amazon.com Services, Inc.

The case began when three Amazon warehouse workers filed a class action lawsuit in Connecticut state court. They worked at Amazon’s BDL2 and BDL3 fulfillment centers in Windsor and North Haven between 2018 and 2021. At the end of every shift, Amazon required them to pass through a security checkpoint before they could leave the building. Depending on what they were carrying, this meant walking through a metal detector, emptying their pockets at a divesting table, or running bags and lunchboxes through an X-ray machine.

Amazon argued it didn’t owe wages for that time, pointing to the U.S. Supreme Court’s 2014 ruling in Integrity Staffing Solutions, Inc. v. Busk, which held that security screenings are non-compensable “postliminary activities” under the federal Fair Labor Standards Act (FLSA) as amended by the Portal-to-Portal Act of 1947. A federal trial court in Connecticut agreed and granted Amazon summary judgment. The workers appealed, and the Second Circuit – recognizing the question as unsettled under Connecticut law – certified two questions to the Connecticut Supreme Court.

What the Connecticut Supreme Court Held

Writing for a unanimous court, Justice Ecker answered both certified questions decisively.

Question One: Is Security Screening Time Compensable Under Connecticut Law?

Yes. The court grounded its analysis in the plain language of Connecticut General Statutes §31-76b(2)(A), which defines “hours worked” to include “all time during which an employee is required by the employer to be on the employer’s premises.” The court held that this language is plain and unambiguous: if the employer requires the employee to be on-premises, that time is compensable – full stop. The statute does not require the employee to be performing productive work during that time; it explicitly includes time spent waiting on the premises when no work is provided.

The court rejected Amazon’s argument that the statute’s use of the word “work” introduced ambiguity. It also distinguished the Appellate Court’s decision in Belgada v. Hy’s Livery Service, Inc., which had addressed the meal-break exception – a separate part of the statute that does require interpretation of the word “work.” The security screening claim, by contrast, turns on the premises-presence clause, not the meal-break clause, so no ambiguity arises.

The court also rejected Amazon’s “absurd results” argument. Amazon contended that broadly defining compensable on-premises time would incentivize malingering (for example, employees taking elevators instead of stairs to run up the clock). The court noted this concern is a matter of legislative policy, not judicial construction, and pointed out that Amazon could simply move its time clocks to a location past the security screening area.

Question Two: Does a De Minimis Exception Apply?

No. Under federal law, an employer may disregard “insubstantial or insignificant periods of time” that cannot practically be recorded for payroll purposes. Connecticut has no equivalent rule – not in statute, not in regulation, and not in judicial precedent.

Amazon argued that Connecticut’s fifteen-minute rounding rule (found in Regs. Conn. State Agencies §§31-60-11(a) and 31-60-12(a)(4)) functionally incorporated the federal de minimis doctrine. The court firmly rejected this conflation. The rounding rule is a procedural mechanism designed to ensure full compensation – time is rounded up or down so that, over time, employees receive all wages earned. The de minimis doctrine, by contrast, is an exception to compensability that allows employers to simply not pay for certain short periods of time. These are opposite in purpose, and the court refused to treat one as incorporating the other.

The court also declined to adopt the de minimis exception as a matter of judicial construction. Neither the Connecticut legislature nor the state Department of Labor – despite having more than sixty years to do so – has codified a de minimis exception. The court held that formulating such a policy exception is the legislature’s prerogative, not the judiciary’s.

Why This Decision Is Significant for Connecticut Workers and Employers

This ruling establishes that Connecticut’s wage laws are meaningfully more protective than the FLSA in two distinct ways. First, the on-premises compensability standard under §31-76b(2)(A) does not incorporate the FLSA’s “integral and indispensable” test from the Portal-to-Portal Act. Where federal law asks whether the activity is closely tied to the employee’s principal duties, Connecticut law asks only one question: did the employer require the employee to be on the premises? If yes, that time must be paid.

Second, Connecticut employers cannot invoke the de minimis doctrine as a shield against wage claims. Every minute of required on-premises time is potentially compensable, regardless of how brief. The statute says “all time” – and the court held that “all” means all.

The practical implications extend well beyond Amazon’s fulfillment centers. Any Connecticut employer that requires employees to remain on-premises for activities after (or before) clocking out – mandatory safety briefings, bag checks, equipment inspections, post-shift meetings, or any other on-site obligation – may be creating compensable time under this standard.

Who May Have a Claim

Workers who may be affected include those who:

• Worked at an Amazon fulfillment center in Connecticut and were subject to end-of-shift security screenings;

• Work for any Connecticut employer that requires on-premises activities after clocking out, such as bag checks, security screenings, or post-shift briefings;

• Were paid using a time-rounding system that may not have captured all required on-premises time.

Wage claims under Connecticut law (§§31-68 and 31-72) may entitle prevailing employees to unpaid straight time and overtime wages at twice the full amount, plus costs and attorney’s fees. The class action vehicle remains available for similarly situated workers.

This blog post is for informational purposes only and does not constitute legal advice. If you have questions about your pay checks or wage rights, please contact our office for a consultation.