Court Grants Summary Judgment to Hospital in Automatic Meal-Deduction Class Action

In the maelstrom of class actions against hospitals for work allegedly performed during meal periods automatically deducted from pay, a ray of sunshine recently emerged as a federal district court granted summary judgment to a hospital. In Haviland v. Catholic Health Initiatives-Iowa, Corp., current and former security guards at three Mercy hospital locations in Iowa filed suit, claiming that their activities during meal period were so restricted that, in essence, they were actually working during the meal periods, which were automatically deducted from their pay.

In deciding the hospital’s motion for summary judgment, the court first assessed whether the hospital’s automatic mealbreak policy was, as the plaintiffs claimed, a per se violation of the Fair Labor Standards Act (FLSA). The security guards alleged that their meal periods should have been paid because they were never completely relieved from duty by another security guard during meal periods and had to remain “present” at the hospital to deter misconduct and respond in the event of an emergency. The court rejected this argument and held that an employee does not have to be “completely relieved from duty” for a meal period to be non-compensable. Instead, the court held, to be compensable, a meal period must be spent predominantly for the benefit of the employer.

Examining the totality of the circumstances, the court analyzed the activities of the security guards during meal periods and the frequency of interruptions and concluded that the guards spent their meal periods predominantly for their own benefit. Although they were required to remain on-site, the guards “were able to enjoy their meal periods in either a break room, office, or squad room, in an environment conducive to reading, studying, or relaxing, and with virtually unlimited access to every form of electronic entertainment and communication.” In addition, the court emphasized, the hospital had a system, which all of the plaintiffs knew of, and which two of the three named plaintiffs had used, to compensate security guards when they were unable to have an uninterrupted meal break. The court noted that “such a system is consistent with the purposes of the FLSA.”

While only one district court’s opinion, this case is very helpful in establishing that an employee need not be “completely relieved from duty” and that a valid meal break exists so long as the period is used predominantly for the benefit of the employee.

This entry was written by Greg Keating.

Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.