You finish your shift at an Amazon warehouse in Windsor, Connecticut. You want to go home. You swipe your badge to clock out. But Amazon says: not yet. You must stand in a security line first. You must pass through metal detectors. If you brought a bag, you must put it through an X-ray machine. If the alarm goes off, you must submit to a secondary screening with a hand-held wand. Only then can you leave the building. Amazon controls your exit. Amazon requires your presence. Amazon does not pay you for this time.

In February 2026, the Connecticut Supreme Court said that practice is illegal under state law. The ruling in Del Rio v. Amazon.com Services, Inc. is a landmark decision that expands worker protections beyond the federal floor and rejects corporate arguments that a few stolen minutes don’t matter.

The Facts: What Amazon Did and Why Workers Sued

Case No. SC 21109 Three Amazon warehouse employees worked at fulfillment centers BDL2 (Windsor) and BDL3 (North Haven) between 2018 and 2021. Amazon required all employees to pass through mandatory security screenings before exiting the building at the end of every shift. The screening process varied depending on what workers carried:

• Express lanes: For workers with no belongings. Walk through a metal detector “without breaking stride.” No additional time required.
• Divesting tables: For workers with small items (keys, coins, wallets). Place items in a basket, walk through metal detector. Estimated time: 10 seconds to 3 minutes.
• X-ray machines: For workers with bags, lunch boxes, or purses. Put items through X-ray while walking through metal detector. Estimated time: 10 seconds to 4 minutes on average, with outlier cases up to 20 minutes.
• Secondary screening: If the metal detector alarmed, workers were subjected to a hand-held wand search. Added time: variable, up to 10 additional minutes.

Amazon employees clocked out before entering the security screening area. The time spent waiting in line and undergoing screening was unpaid. Amazon discontinued the screenings in March 2020 due to the COVID-19 pandemic, but the legal question remained: was the time spent in those lines compensable under Connecticut wage laws?

Javier Del Rio, Colin Meunier, and Aaron Delaroche filed a class action lawsuit in Connecticut Superior Court in August 2021 on behalf of all hourly, non-exempt warehouse workers employed at Amazon facilities in Connecticut from April 16, 2018, through the date of final judgment. They argued that the time spent undergoing mandatory security screenings was compensable under General Statutes §31-76b(2)(A), which defines “hours worked” as including “all time during which an employee is required by the employer to be on the employer’s premises.”

The Misconduct: How Amazon Used Federal Loopholes to Dodge State Law

Corporate Defense Strategy Amazon removed the case to federal court and moved for summary judgment, arguing two main defenses:

Defense 1: Federal Law Says Security Screenings Are Not Compensable

Amazon relied on Integrity Staffing Solutions, Inc. v. Busk, a 2014 U.S. Supreme Court decision holding that mandatory security screenings are not compensable under the Fair Labor Standards Act (FLSA) as amended by the Portal-to-Portal Act of 1947. The Portal-to-Portal Act exempts “activities which are preliminary to or postliminary to” an employee’s principal work activities. Security screenings, the Supreme Court held, are “postliminary” because they are not “integral and indispensable” to warehouse work.

Amazon argued that Connecticut wage laws were “intended to be coextensive with federal overtime law” and therefore should be interpreted to exclude security screenings from compensability, just like federal law does.

Defense 2: Even If Compensable, the Time Was “De Minimis”

Amazon argued that even if security screening time was otherwise compensable, it should be treated as “de minimis”—too trivial to require payment. Under federal regulations (29 C.F.R. §785.47), employers can disregard “insubstantial or insignificant periods of time beyond the scheduled working hours, which cannot as a practical administrative matter be precisely recorded for payroll purposes.”

Amazon pointed to video evidence showing that most screenings took only 10 seconds to 3 minutes and argued that this time was too minor to track or compensate.

The U.S. District Court for the District of Connecticut agreed with Amazon and granted summary judgment in the company’s favor in 2023. The workers appealed to the Second Circuit Court of Appeals, which certified two questions of law to the Connecticut Supreme Court:

1. Under Connecticut’s wage laws and regulations, must employees be compensated for the time spent going through mandatory security screenings at their place of employment?
2. Does a de minimis exception apply, and, if so, what factors should be considered in determining whether the uncompensated time is de minimis?

The Legal Receipts: What the Connecticut Supreme Court Actually Said

“The plain language of §31-76b(2)(A) requires that, with the exception of meal breaks, employers compensate their employees for four categories of time: (1) when the employer requires the employee to be on the employer’s premises, (2) when the employee is on duty, (3) when the employer requires the employee to be at the prescribed work place, and (4) when the employee is employed or permitted to work, whether or not required to do so.”

“Because Amazon required the plaintiffs to undergo mandatory security screenings on the premises of its fulfillment centers before permitting them to leave the buildings at the conclusion of their shifts… this time was compensable under the plain and unambiguous language of §31-76b(2)(A).”

Question 1: Compensability The Court answered the first certified question in the affirmative. Connecticut law does require employers to compensate employees for time spent in mandatory security screenings on the employer’s premises. The statute is plain and unambiguous: if an employer requires you to be on their premises, that time counts as “hours worked,” even if you are not performing job duties.

“‘[H]ours worked’ include all time during which an employee is required by the employer to be on the employer’s premises,” including “the time when an employee is required to wait on the premises while no work is provided by the employer.” General Statutes §31-76b(2)(A).

The Court rejected Amazon’s argument that the statute was ambiguous because the word “work” was undefined. The operative phrase is “hours worked,” and the statute defines it explicitly. The definition of “work” in isolation is irrelevant when the statute already tells you what compensable time includes.

“Except for meal breaks, which are not at issue in this appeal, the definition of ‘work’ is irrelevant to the compensability of the time that employers require their employees to spend on the employers’ premises under §31-76b(2)(A).”

The Court also rejected Amazon’s claim that interpreting the statute this way would lead to “absurd or unworkable results.” Amazon argued it would be impractical to track security screening time and that employees could exploit the rule by intentionally wasting time. The Court found these arguments unpersuasive.

“Amazon has not offered a reason, and we cannot think of one, why it could not place its time clocks at a location outside of the security screening area rather than inside of that area, so that employees could clock out from their shifts after undergoing the mandatory security screening process.”

Question 2: De Minimis Exception The Court answered the second certified question in the negative. Connecticut wage laws do not incorporate a de minimis exception to compensability.

“We find no support in our statutes, regulations, or case law for the recognition of a de minimis exception in the present context.”

Amazon argued that the fifteen-minute rounding rule in Connecticut regulations (§31-60-11(a) and §31-60-12(a)(4)) implicitly incorporated the de minimis exception. The Court disagreed. The rounding rule and the de minimis exception serve different purposes. The rounding rule allows time to be rounded to the nearest fifteen-minute increment to simplify recordkeeping, but it still requires full compensation over time. The de minimis exception, by contrast, allows employers to disregard certain time periods entirely without compensation.

“The rounding rule is not an exception to compensability. To the contrary, it is a procedural mechanism intended to result in full compensation.”

The Court also rejected Amazon’s reliance on prior Connecticut case law. Amazon cited Sarrazin v. Coastal, Inc. (2014) and Nettleton v. C & L Diners, LLC (2023), but the Court clarified that neither case addressed whether Connecticut law incorporates a general de minimis exception. Sarrazin discussed the de minimis exception only in the context of federal law, and Nettleton assumed the exception applied without analyzing whether it had been adopted under Connecticut law.

“Nettleton never addressed the issue before us, which is whether Connecticut’s wage laws incorporate the federal de minimis exception, because, in that case, the parties did not raise, brief, or argue that issue.”

The Non-Financial Ledger: Dignity, Control, and the Theft of Time

The legal outcome is clear, but the human dimension of this case reveals a deeper structural injustice. Amazon warehouse workers are not just employees performing tasks for wages. They are human beings whose time—their most finite and irreplaceable resource—is controlled by a corporation that treats minutes as expendable.

Consider what it means to be required to stay on an employer’s premises after you have clocked out. You are no longer being paid. You are no longer working. But you are not free to leave. You must stand in a line. You must wait. You must submit to a search. Your time is not your own. Amazon has taken it, and under the federal system Amazon preferred, they would not have to give you anything in return.

Aaron Delaroche testified that the screenings usually took “three minutes or less,” but one time it took an estimated twenty minutes. Colin Meunier said the longest he ever waited was ten minutes. Javier Del Rio’s experience was similar. These are not uniform, predictable delays. They are variable, unpredictable impositions on workers’ personal time.

What do you do with three uncompensated minutes? What do you lose when twenty minutes are taken from you without consent and without pay? You miss the bus. You are late to pick up your child. You lose time with your family. You are held captive, not by bars or chains, but by corporate policy and the implicit threat of termination if you refuse to comply.

Amazon’s argument—that this time was “de minimis,” too trivial to matter—reflects a worldview in which the time of workers is worth less than the administrative convenience of the employer. The Connecticut Supreme Court rejected that worldview.

“By requiring its employees to remain on the premises of its fulfillment centers during the mandatory security screening process, Amazon deprives its employees of time that would otherwise be their own.”

This case is not just about wages. It is about power. It is about who gets to decide what your time is worth and whether you have any control over your own life once you leave the workstation.

Societal Impact Mapping

Economic Inequality: The Aggregation of Stolen Seconds

Amazon argued that because each individual instance of unpaid time was small, the total harm was insignificant. But wage theft operates through aggregation. A few minutes per worker per shift becomes hours per week, days per year, weeks over a career. Multiply that across thousands of workers in Connecticut alone, and the scale of the theft becomes apparent.

The plaintiffs sought to represent a class of all hourly, non-exempt warehouse workers employed by Amazon in Connecticut from April 16, 2018, through the date of final judgment. Amazon employed these workers at multiple facilities over a period of years. Even at the low end of the time estimates—ten seconds per screening—the cumulative unpaid time represents a significant transfer of value from workers to the corporation.

Amazon’s 2023 annual revenue: $574.8 billion. The cost of paying workers for security screening time: a rounding error in the balance sheet. The refusal to pay: a choice.

Public Health: The Invisible Stress of Unpredictability

Unpaid, uncompensated time creates stress. Workers cannot accurately predict when they will be free to leave. They cannot plan their lives around a predictable schedule. A screening that usually takes three minutes might take twenty. That variability imposes a psychological burden that is not captured in any wage calculation.

The inability to control your own time is linked to increased stress, anxiety, and burnout. It erodes the boundary between work and personal life. It makes workers feel powerless. These are public health harms that do not appear in any corporate cost-benefit analysis.

Environmental Degradation: The Carbon Cost of Captivity

When workers are held on-site longer than necessary, they burn more fuel commuting at peak traffic times. When workers cannot leave predictably, they cannot carpool efficiently or coordinate shared transportation. The environmental cost of Amazon’s unpaid security screenings is diffuse and unquantified, but it is real. Every minute a worker is forced to stay on-site is a minute they could have spent reducing their carbon footprint by leaving earlier or using alternative transportation.

What Now? Leadership, Watchlists, and Resistance

Corporate Leadership Amazon.com Services, LLC (formerly Amazon.com Services, Inc.) is the named defendant. Amazon.com, Inc. is the indirect parent corporation. Amazon.com.dedc, LLC merged into Amazon.com Services, Inc. in 2019. The legal entities are layered, but the control is centralized.

No individual executives are named in this decision, but the mandatory security screening policy was implemented and enforced by Amazon management at the BDL2 (Windsor) and BDL3 (North Haven) fulfillment centers between April 2018 and March 2020.

Regulatory Watchlist This case clarifies the scope of Connecticut General Statutes §31-76b(2)(A) and the regulations at §31-60-11(a) and §31-60-12(a)(4). The following agencies have jurisdiction over enforcement:

• Connecticut Department of Labor, Wage and Workplace Standards Division: Enforces state wage laws and investigates wage theft complaints.
• Connecticut Attorney General’s Office: Can bring enforcement actions for systemic wage violations.
• U.S. Department of Labor, Wage and Hour Division: Enforces federal FLSA standards, which now serve only as a floor, not a ceiling, in Connecticut.

What Workers Can Do If you work in Connecticut and your employer requires you to remain on-site for any reason after you clock out—security screenings, equipment checks, bag searches, exit interviews, waiting for management approval to leave—that time is compensable under state law. Document everything. Record the time you clock out and the time you are actually permitted to leave the premises. File a wage complaint with the Connecticut Department of Labor. Contact a labor attorney. Organize with your coworkers.

Amazon is not the only employer that has tried to steal time by calling it trivial. This ruling applies to all employers in Connecticut. Use it.

Mutual Aid and Organizing This case was brought as a class action by three named plaintiffs on behalf of all similarly situated workers. That is the power of collective legal action. But litigation is slow and expensive. Organizing is faster. Join or form a union. Connect with worker centers and labor rights organizations in your area. Build power with your coworkers. The law is on your side, but the law does not enforce itself.