You Clocked Out. Amazon Kept Your Time.

EvilCorporations.com • Case No. 23-1337 • 2nd U.S. Circuit Court of Appeals • 19 min read

The Non-Financial Ledger: What Numbers Don’t Cover

Picture the end of a long shift at an Amazon fulfillment center. Your feet hurt. Your back hurts. You have clocked out. The system says your workday is over. But you cannot leave. Not yet. You have to walk to the security checkpoint, get in whatever line fits what you happen to be carrying, and wait for Amazon’s security apparatus to decide it is done with you.

This was the daily reality for workers at BDL2 in Windsor, Connecticut and BDL3 in North Haven, Connecticut from April 2018 until March 2020, when the COVID-19 pandemic forced Amazon to suspend the practice. You did not go through this screening when you arrived for your shift. Only when you tried to leave. The direction of suspicion was not subtle: Amazon trusted you enough to let you in without a search, but not enough to let you out without one.

If you carried nothing in your pockets, you could use the express lane and walk straight through a metal detector. That was the fastest option. If you had anything in your pockets, you stopped at a divesting table, emptied them into a basket, sent it through separately, and walked through the detector yourself. If you brought a bag, a lunchbox, or a purse, that item went through an X-ray machine while you walked through the metal detector. And if anything set off an alarm, you were pulled aside for a secondary screening where a security guard physically wanded you.

Now consider what this looks like at scale. Hundreds of workers ending their shifts at the same time, all moving toward the same checkpoints, all carrying the accumulated small necessities of a workday. Javier Del Rio, Colin Meunier, and Aaron Delaroche did not just experience this once. They experienced it every single time they attempted to leave the secured area, which included every break where the breakroom was located outside the secured zone.

One of the three plaintiffs testified that on a typical run through, the process took roughly ten seconds. Another said the maximum he ever endured was ten minutes, with a general range he described as three to four minutes at the high end. Ten seconds sounds like nothing. Ten minutes, unpaid, after you have already clocked out, with no ability to leave your employer’s premises until they say so, is something else entirely. And the ten-second runs did not eliminate the ten-minute days. Both existed. Neither was compensated.

The law that Amazon pointed to in its defense was a federal statute called the Portal-to-Portal Act, which was amended decades ago partly in response to corporate lobbying to narrow what counts as paid work time. Amazon argued that because the U.S. Supreme Court ruled in 2014 (in a case called Integrity Staffing Solutions, Inc. v. Busk) that mandatory security screenings are not compensable under federal law, Connecticut workers should be treated the same way. The district court agreed and dismissed the case entirely. What this meant in practice was that a federal judge applied a federal statute designed to limit worker pay rights to workers who had specifically filed under Connecticut law, a state that explicitly wrote its wage statutes as remedial measures designed to penalize employers who shortchange workers.

The Second Circuit would not let that stand without a fight. Three federal appellate judges looked at Connecticut’s own definition of “hours worked,” which includes time employees are required to be on the employer’s premises even when no work is being provided, and found that the district court’s conclusion was far from certain. They refused to hand Amazon a final ruling. Instead, they passed the question to the Connecticut Supreme Court, which is where it belongs.

What Del Rio, Meunier, and Delaroche built, by filing that complaint and appealing that dismissal, is now a precedent-setting gateway case that could unlock back pay for an entire class of Connecticut workers, and set a floor for how future employers may not design their security systems to quietly steal time from the people who make their warehouses run.

Legal Receipts: What the Court Documents Actually Say

These are direct quotes from Case No. 23-1337, Del Rio et al. v. Amazon.com.dedc, LLC et al., decided March 17, 2025 by the Second Circuit Court of Appeals. Nothing paraphrased. Nothing invented.

“Amazon arranged the timeclocks within the fulfillment centers so that employees had to clock out before going through security. Employees were therefore not compensated for time they spent undergoing the security screening procedures.”

— Second Circuit Court of Appeals, Case No. 23-1337, Section I(A)

• This is not an accident or an oversight. Amazon deliberately engineered the physical layout of its warehouses so the clock-out point came before the screening, guaranteeing the screening time fell outside paid hours. This was a structural wage decision, not a scheduling technicality.
• The court states this as a factual finding, not an allegation. Amazon does not dispute the arrangement. The only dispute was whether it was legal.

“This included any time employees attempted to access breakrooms outside the secured area or to leave the facility during their breaks or at the end of their shift.”

— Second Circuit Court of Appeals, Case No. 23-1337, Section I(A)

• The unpaid screening requirement was not limited to end-of-shift departures. Workers had to go through it every time they left the secured area for any reason, including to use a breakroom located outside the secured perimeter.
• This means the unpaid time accumulated multiple times per shift for any worker whose break facilities were on the outside of the secured zone.

“One estimated that he spent ‘an average of ten (10) seconds’ going through the security screening, while another estimated that the ‘maximum estimate for time spent in security . . . was three to four minutes’ and ‘the longest he ever spent . . . was 10 minutes.'”

— Second Circuit Court of Appeals, Case No. 23-1337, Section III(C)

• The wide variation in screening times is legally significant. It directly informs the second certified question: whether any “de minimis” exception should excuse Amazon from paying. Ten seconds might arguably be trivial; ten minutes, repeated across multiple exits per shift, across years, across hundreds of workers, is not.
• The court notes that the Connecticut Appellate Court has confirmed there is “no rigid rule” and “no precise amount of time” that can automatically be written off as de minimis. Each case requires common sense analysis of the specific facts.

“[S]everal other states rejected the Busk approach and determined that their state wage laws demand that employers compensate their employees for time spent in mandatory security screenings, even if federal law does not.”

— Second Circuit Court of Appeals, Case No. 23-1337, footnote 7

• The court specifically cites Pennsylvania, whose Supreme Court ruled that time spent undergoing mandatory screenings on an employer’s premises was compensable under state law. It cites Maryland for similarly ruling that state wage law’s definition of “work” is broader than the federal standard.
• Amazon’s argument that federal law settles the question is directly contradicted by existing precedent in multiple states. Connecticut is not obligated to follow the federal floor if its own laws provide greater protection.

“Connecticut’s statute prescribing a cause of action for wage claims was enacted as a ‘remedial statute,’ with a ‘primary purpose’ being to ‘penalize . . . employers.'”

— Second Circuit Court of Appeals, citing Butler v. Hartford Tech. Inst., Inc., 704 A.2d 222 (Conn. 1997)

• Connecticut’s own Supreme Court has already described the state wage law as a tool designed to punish employers who underpay workers, not simply to create a neutral accounting standard.
• This framing directly weakens Amazon’s argument that Connecticut would naturally defer to the more employer-friendly federal standard. The state legislature wrote its wage law to be a penalty statute. That matters.

Societal Impact: Who Gets Hurt When Amazon Steals Minutes

Public Health

Wage theft does not just reduce paychecks. It degrades the physical and psychological health of workers in ways that compound over time.

• Workers at Amazon fulfillment centers perform physically demanding labor. Adding unpaid mandatory wait time at the end of a shift extends total time on-site without compensation, eroding the ratio of pay to physical cost and compressing the time workers have to recover before the next shift.
• The screenings applied to break periods, not only end-of-shift exits. A worker attempting to leave the secured area during a break had to queue, be screened, take whatever remained of the break, and then re-enter the secured area. Effective break time was therefore shorter than scheduled, unpredictably so depending on queue length.
• Workers who were “wanded” during secondary screening after setting off an alarm experienced a direct, physical assertion of suspicion by their employer after already clocking out. This kind of routine surveillance and implied distrust has documented links to workplace stress and burnout, particularly in lower-wage labor environments.
• The practice ran from April 2018 to March 2020 and had not resumed as of the deposition period. Workers who experienced the longest screenings, up to ten minutes, with no compensation, were absorbing that time and its associated stress as a pure cost of employment.

Economic Inequality

Warehouse workers are among the lowest-paid members of the labor force. Systematically denying them pay for mandatory on-premises time compounds an already severe wealth gap between Amazon’s executives and its floor workers.

• Amazon is the second-largest private employer in the United States. At scale, even a few unpaid minutes per worker per shift, multiplied across hundreds of workers at two Connecticut facilities alone, represents a significant transfer of value from labor to the corporation. None of that transfer was disclosed to workers as a wage deduction; it was simply engineered out of existence by placing the clocks on the wrong side of the checkpoint.
• The workers who filed this case were doing so under Connecticut’s wage statutes that explicitly allow claims for both straight-time and overtime wages. The overtime component is particularly significant: if screening time pushed a worker past 40 hours in a week, the unpaid premium rate (time-and-a-half) was also stolen, not just base wages.
• The case was filed as a class action on behalf of all similarly situated current and former Amazon employees at these facilities. The individual amounts may appear small, but class-wide, they represent potentially years of accumulated unpaid labor across hundreds of workers.
• At least two other federal cases in Connecticut, one against FedEx and one against Walgreens, raise the same “hours worked” question. The ruling in this case functions as economic policy for an entire category of hourly workers in the state. One of those cases is stayed, meaning those workers are waiting for justice that is itself waiting on a legal answer.
• Connecticut’s wage statute was designed as a remedial and penalty statute, according to the Connecticut Supreme Court’s own prior ruling. The fact that a district court applied a federal narrowing doctrine to a state penalty statute, effectively nullifying the penalty before it could be assessed, inverted the law’s stated purpose entirely.
• States like Pennsylvania have already ruled that Amazon owes workers for this time. A Pennsylvania worker who did the same job in the same type of warehouse with the same security screening was legally owed compensation that a Connecticut worker was being denied until this appeal forced the question to be properly decided.

The “Cost of a Life” Metric: Quantifying the Theft

The court record does not include a total dollar figure for unpaid wages. What it does document is the architecture of the theft and its potential scope.

What Now: The Case Is Not Over, and Neither Is the Fight

The Second Circuit’s March 2025 ruling does not hand workers a win; it keeps the door open. The Connecticut Supreme Court now holds the decision.

Key Defendants in This Case

• Amazon.com Services LLC: The direct employer. Operated BDL2 and BDL3. Designed the clock placement that put workers in unpaid screenings.
• Amazon.com, Inc.: The indirect parent corporation. Named as a defendant. Did not directly employ the plaintiffs but is part of the corporate structure enabling this policy.
• Amazon.com.dedc, LLC: The entity that employed Colin Meunier before it merged into Amazon.com Services Inc., which later became Amazon.com Services LLC.

The Watchlist: Bodies That Should Be Watching This

• Connecticut Department of Labor (CT DOL): The state agency responsible for enforcing Connecticut’s wage statutes. The outcome of the certified questions to the CT Supreme Court will directly shape how CT DOL interprets “hours worked” for future enforcement actions against warehouse employers throughout the state.
• U.S. Department of Labor, Wage and Hour Division (WHD): Federal enforcement of the Fair Labor Standards Act. While federal law (after Busk) does not require pay for security screening time, the WHD monitors state-law developments that define how the FLSA’s floor interacts with state ceilings.
• Connecticut Supreme Court: The court now holding the certified questions. Its answers on whether screening time is compensable and whether a de minimis exception applies will be binding on all future Connecticut wage cases involving mandatory on-premises time post-clock-out.
• U.S. District Court, District of Connecticut: The trial court where FedEx (Alfonso v. FedEx Ground) and Walgreens (Johnson v. Walgreen E. Co.) cases are pending. Johnson is stayed pending the outcome of this certification. Those workers are waiting.
• Federal Trade Commission (FTC): Amazon’s market dominance and labor practices remain under broader scrutiny. The company’s ability to architect wage systems that extract unpaid labor at scale is part of the larger monopoly-power conversation.

What You Can Do Right Now

• If you are or were an Amazon warehouse worker in Connecticut: You may be a member of this class. Contact plaintiff’s counsel Hayber, McKenna and Dinsmore LLC in Hartford, CT. The case is still active and the class period covers April 2018 through at least March 2020.
• Document your own clock-out practices: If you work in a warehouse or retail environment anywhere and are required to undergo screenings, security checks, or any mandatory process after clocking out, document the time. Write down dates, times, and durations. This is the evidence that wins class actions.
• Connect with warehouse worker organizing networks: Organizations like Warehouse Workers United, Athena (a coalition focused on Amazon’s labor and community impact), and local affiliates of the Teamsters or RWDSU are actively tracking cases like this. Find your nearest chapter and share this information.
• Support state-level wage legislation: Several states have moved faster than the courts by passing explicit laws requiring payment for all mandatory on-premises time. Contacting your Connecticut state legislators to push for a statutory fix, rather than waiting for years of litigation, is a faster path to protection for current workers.
• Share this case with other hourly workers: Most workers do not know that the time they spend in mandatory processes after clocking out may legally be compensable. Information is organizing. Every person who reads this and recognizes their own situation is a potential plaintiff or witness.