In White v. Baptist Memorial Health Care Corporation, 2012 U.S. App. LEXIS 22752 (6th Cir. 2012), the U.S. Court of Appeals for the Sixth Circuit held that, if an employer establishes a reasonable process for an employee to report work performed during unpaid breaks, it is not liable for non-payment if an employee fails to report the work performed through the established process. This is a welcome decision for employers, who increasingly are targeted with claims that they “should have known” about unreported off-the-clock work allegedly performed by employees. To learn more about the decision, please continue reading at Littler’s Healthcare Employment Counsel.