unpaid wages legal defense Maryland

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Maryland’s High Court Gives Employers a Small Win: The “De Minimis” Doctrine Applies to Wage Claims

In a closely watched class-action case involving Amazon, the Maryland Supreme Court recently ruled that the “de minimis” doctrine—which allows courts to disregard trivial claims—applies to Maryland’s wage and hour laws. This decision offers a measure of relief to employers who might otherwise face lawsuits over a few minutes of uncompensated time. From an employment law perspective, this decision is a reminder of how Maryland courts are working to strike a balance between protecting employees’ rights and recognizing the realities of today’s workplaces. While Maryland is known for its strong worker protections, this ruling signals that not every second of time under an employer’s control automatically gives rise to liability. What Happened? The case centered on whether Amazon employees should be paid for the time they spent going through mandatory security screenings after clocking out at a Baltimore fulfillment center. The wait times ranged from a few minutes to more than 15 minutes. The lead plaintiff, Estefany Martinez, argued this time was compensable work. Amazon argued—and the Court agreed—that the de minimis doctrine, long recognized in federal law, applies under Maryland’s Wage Payment Collection Law and Wage and Hour Law. In other words, Maryland employers aren’t required to track and pay for every split second of time, especially when it’s difficult to measure or so minimal that it becomes unreasonable to enforce. What This Means for Maryland Employers This is a narrow victory for employers—but one that shouldn’t be misinterpreted as a green light to ignore small increments of time worked. The Court made clear that some time may still be compensable, even if short, depending on the facts. In other words, “de minimis” doesn’t mean “no liability”—it means “not always.” As employment attorneys, we advise our clients to take a proactive approach to wage and hour compliance. Here are a few takeaways for Maryland employers: Security screenings and similar activities may still be compensable if they exceed trivial time thresholds or occur regularly. Policies should clearly define compensable and non-compensable time—and be consistent with how time is tracked and paid. Class action risk remains if employers fail to evaluate how cumulative unpaid time could add up across a workforce. Employers should remember that state and federal wage laws are interpreted independently, and this ruling doesn’t change federal standards under the Fair Labor Standards Act. A Word of Caution In a strong dissent, two justices argued that even short periods of unpaid work may run afoul of Maryland’s wage laws. Advocates also warn that incorporating the de minimis doctrine could create a slippery slope that allows employers to sidestep responsibility for small but meaningful pockets of unpaid labor. So while this decision may provide breathing room, it’s no excuse for lax timekeeping practices. The safer course? If the time is measurable, regular, and required by the employer—it’s probably compensable. Need Guidance? If you have questions about how this ruling affects your business, or if you want to evaluate your current wage and hour policies for compliance with Maryland law, Luchansky Law is here to help. We work with employers across the state to stay ahead of evolving legal standards—and avoid costly class-action pitfalls. Contact Luchansky Law at (410) 522-1020 or visit https://employmentattorneymd.com/     Reference Links: Maryland Supreme Court opinion (via Maryland Judiciary or news source):https://mdcourts.gov/opinions (search for the case involving Estefany Martinez v. Amazon) Relevant Federal Case Law (Anderson v. Mt. Clemens Pottery Co.):https://supreme.justia.com/cases/federal/us/328/680/ Maryland Wage and Hour Law overview:https://www.dllr.state.md.us/labor/wages/wagehrfacts.shtml

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