On February 10, 2026, the Connecticut Supreme Court ruled in Del Rio v. Amazon.com Services, Inc., 354 Conn. 151 (2026), that, under Connecticut’s wage and hour laws, Amazon’s warehouse employees must be compensated for time spent undergoing security screenings at the conclusion of their work shifts. In its decision, the Court also declined to incorporate the de minimis doctrine, recognized under federal law, into Connecticut law, instead determining that, if an employee performs compensable work of any duration, the employee must be paid.

This lawsuit was filed by three warehouse employees who worked in Amazon’s fulfillment centers in Connecticut between 2018-2021. Their class action complaint, filed on behalf of themselves and similarly situated employees, alleged Amazon failed to pay employees wages for time spent undergoing security screenings at the end of their work shifts. Evidence showed those screenings could last from a few seconds to, in some situations, up to 20 minutes for employees carrying personal items like backpacks, lunch containers, or purses. Amazon argued that the time spent screening was not compensable as work time under Connecticut law and, even if it was work time, the amount of time was de minimis and need not be paid to them. 

As explained by the Court, Connecticut General Statutes § 31-71b required Amazon to pay the warehouse workers based on their hours worked and § 31-76b(2)(A) defined the term “hours worked” as “all time during which an employee is required by the employer to be on the employer’s premises or to be on duty, or to be at the prescribed work place, and all time during which an employee is employed or permitted to work, whether or not required to do so…. Such time includes, but shall not be limited to, the time when an employee is required to wait on the premises while no work is provided by the employer.” The Court determined that, since Amazon required the employees to wait on the premises after the conclusion of their scheduled shifts and undergo security screenings, they were required to be paid for such time. 

In rejecting Amazon’s assertion that Connecticut law incorporates the de minimis doctrine, the Court noted that the doctrine, as codified in the regulations for the federal Fair Labor Standards Act, 29 C.F.R. § 785.47, expressly allows employers to disregard insubstantial and insignificant periods of time if those periods of time cannot, as a practical administrative matter, be precisely recorded for payroll purposes. But no statute, regulation, or judicial precedent in Connecticut recognizes that doctrine.   

This decision is an important reminder for businesses with employees in Connecticut to ensure that their employees are paid for all hours of work and further that employers cannot any longer argue that otherwise compensable work time may be disregarded as de minimis time. Indeed, with the prevalence of electronic timekeeping systems that track employee work time precisely, this case also foretells employers of the risks of class action lawsuits they may face if they do not pay employees for all time worked.