Jan 25, 2024

CRST Team Drivers' Right to Compensation for Sleeper Berth Hours Upheld

In the ever-evolving landscape of employment law, one crucial aspect continues to be the right to fair compensation for hours worked. This is especially true in the trucking industry, where long hours per day and extended periods away from home are a common reality for many drivers.

In a recent case, the CRST Team Drivers' right to compensation for sleeper berth hours has been upheld, providing a significant win for motor carrier truck drivers across the country. This decision has the adverse effects and potential to impact the industry as a whole, setting a precedent class actions for fair pay and acknowledging the value of non-driving work time for truck drivers.

In this article, we will explore the details of this case and the implications it may have for both CRST Team Drivers and other drivers in the industry.

We will also discuss the importance of fair compensation for all hours worked and the significance of this ruling for the trucking community. With a professional tone, we aim to provide a comprehensive overview of this groundbreaking decision and its potential impact.

Must Be Paid According To Federal Minimum Wage Laws

According to a recent decision from the 1st Circuit appellate court, truck drivers who work in teams must be paid according to federal minimum wage laws for the time they spend in the sleeper cab, even if they are not actually sleeping. This case involves carrier CRST, which had previously lost the lawsuit in the U.S. District Court for Massachusetts.

The lawsuit was filed in 2016 by several CRST drivers, with Juan Carlos Montoya as the lead plaintiff. CRST appealed the case to the 1st Circuit.

This decision is potentially groundbreaking as the appeals court suggests that no court has ever ruled on whether team drivers should be compensated for time spent in the sleeper berth that is not considered part of the eight hours of sleep time required by federal law. The three-judge panel noted in a footnote that no published circuit court decisions have been found addressing this specific issue under the Fair Labor Standards Act.

A Significant Case

While litigation over sleeper berth time and compensation is not new, a significant case involving Walmart and several key industry players previously focused on solo drivers rather than team drivers. Team drivers are typically paired together to ensure continuous operation of the trucks and to minimize downtime due to federal hours-of-service rules regulations.

The central question in the lower court and on appeal was whether the time spent by these long-haul drivers in the sleeper berth should be classified as "on-duty" time, as defined by Department of Labor regulations. If so, the court needed to determine whether CRST is obligated to compensate drivers who are on duty time or duty period for 24 hours or more for the time they spend in the sleeper berth that exceeds eight hours within a full 24-hour period.

Should Not be Considered As Work Hours

CRST's stance was that the time spent in the sleeper berth should not be considered as work hours that require compensation. Additionally, the plaintiffs did not make a case for being compensated for the eight hours of mandated daily sleep time. The main point of contention revolved around differentiating between the drivers for time spent driving or working, which can go up to 14 hours as per Hours of Service (HOS) regulations, and the remaining 16 hours after deducting the eight-hour sleep time from the day's total 24 hours.

A footnote in the appellate court decision clarified the potential consequences. During Montoya's initial pay period, when he was part of a training program and being paid only 25 cents per mile, he received $233.38 along with a $100 signing bonus. While his hourly wage for the actual hours worked exceeded $10 per hour during this trip, the court noted that if the "excess sleeper berth time" was considered compensable, his hourly wage would have fallen below the federal minimum of $7.25 per hour.

The appeals court ruling stated that the time spent in the sleeper berth by the second driver, who was not driving at the time, should not be considered as true free time. It referred to a Supreme Court interpretation of the Fair Labor Standards Act, which defines work as any physical or mental exertion controlled or required by the employer, pursued primarily for the employer's benefit. This interpretation is commonly referred to as the "predominant benefit test," where time spent primarily benefiting the employer is considered as work.

To illustrate this concept, the court provided an example: firefighters playing cards in a firehouse are doing so because they are waiting to respond to an emergency and should be compensated for that time. On the other hand, police officers who are on call but free to engage in any activity as long as they can promptly respond to an emergency do not require equal compensation.

CRST contended that the driver in the sleeper berth is essentially "waiting to be engaged" and therefore should not receive payment.

Drivers Can Engage In Various Activities

According to the court's summary of CRST's arguments, they claimed that drivers can engage in various activities such as sleeping, cooking, watching TV, and using the internet while in the sleeper berth. However, the plaintiffs argued that being confined to this limited space primarily benefits the employer and should be considered compensable work.

The appellate court bluntly disagreed with CRST's perspective, emphasizing the inherent limitations of the drivers' physical location. They highlighted that although drivers may have some leisure activities available, these activities are constrained by their presence in the sleeper berth of a moving truck. This space is small and only contains basic living essentials, and drivers are unable to leave until the truck comes to a stop.

To support their ruling, the 1st Circuit appeals judges referred to a longstanding Supreme Court precedent called Armour from 1944. They pointed out that CRST's argument failed to consider the Supreme Court's established jurisprudence, which states that the ability to engage in leisure activities alone does not automatically classify the time as being for the employee's own benefit.

In Conclusion

The recent court decision upholding CRST Team Drivers' right to compensation for sleeper berth hours is a significant victory for the trucking industry. This ruling not only protects the rights and well-being of drivers, but also sets an important precedent for fair compensation and treatment of essential workers.

As the trucking industry continues to face challenges and changes, it is crucial to prioritize the rights and safety of those who keep our economy moving. The court's decision serves as a reminder of the importance of advocating for fair treatment and compensation for all workers in the trucking industry.

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