Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946), is a decision by the US Supreme Court that held that preliminary work activities, if controlled by the employer and performed entirely for the employer's benefit, are properly included as working time under Fair Labor Standards Act. The decision is known as the "portal to portal case."
The Supreme Court reaffirmed Anderson v. Mt. Clemens Pottery in its 2016 ruling in Tyson Foods, Inc. v. Bouaphakeo, No. 14-1146 (March 22, 2016).
Background
The United States Congress passed the Fair Labor Standards Act (FLSA) in 1938. Section 7(a) of the Act defined working time, and required employers to pay overtime wages under certain circumstances. Section 11(c) of the Act requires employers to keep accurate records regarding time on the job. Section 16(b) of the Act enables employees to sue to recover lost wages.
About 1,200 workers at the Mt. Clemens Pottery Co. facility in Mount Clemens, Michigan, were employed at a large, facility. The plant was nearly a quarter-mile in length. The employees' entrance was in the northeast corner.
Employees were given 14 minutes between each shift to punch the time clock, walk to their respective workbench and prepare for work. It took a minimum of eight minutes for all the employees to get by the time clock. The estimated walking time for employees ranged from 30 seconds to three minutes, but some workers needed as many as eight minutes to reach their workbenches. Upon arriving at their workbench, employees were required to put on aprons or overalls, removed shirts, tape or grease arms, put on finger cots, prepare equipment, turn on switches, open windows, and/or assemble or sharpen tools. Such preparatory activities consumed three to four minutes.
Working time was calculated by the employer based on the time cards punched by the clocks. The employer deducted walking and preparatory time from the time cards based on the punched time and assumptions about how long prep work and walking would take on average.
Seven employees and their labor union (represented by Edward Lamb) brought a class action suit under Section 16(b) of the FLSA alleging that the employer's calculations did not accurately reflect the time actually worked and that they were deprived of the proper amount of overtime compensation.
Special master's findings
The district court appointed a special master to investigate the case. The special master recommended that the case be dismissed because the employees did not establish by a preponderance of evidence a violation of the Act. The special master concluded that walking time was not traditionally held to be compensable working time in the industry, that the employees had produced no reliable evidence to determine how much time they had lost, and that the employees had not shown that they were forced to wait until starting time.
District court's ruling
The district court agreed, with one exception. The court found that the vast majority of employees were ready for work approximately five minutes before the start of work and that it seemed unreasonable that employees would not begin work as they were paid by piece rate. The court fashioned a formula for computing which employees were forced to wait. The district court then entered a judgment against Mt. Clemens Pottery Co. in the amount of $2,415.74.
Court of appeals' ruling
The Sixth Circuit Court of Appeals upheld the district court in part, and overruled the district court in part. The court of appeals upheld the district court and special master by concluding that the employees' claims were not supported by the evidence. However, the court of appeals ruled the district court had erred by assuming that work would begin before the official start of working time. The court of appeals further held that the burden rested upon the employees to prove by a preponderance of the evidence that they did not receive the wages to which they were entitled.
The workers appealed to the Supreme Court, which granted certiorari.