The United States Court of Federal Claims has ruled that correctional officers at the Federal Correctional Institution Mendota in California are entitled to overtime pay for time spent undergoing mandatory security screenings before their shifts. This decision affects current and former employees who allege they have worked unpaid hours beyond their scheduled shifts. The ruling is significant as it clarifies the compensability of pre-shift activities under the Fair Labor Standards Act (FLSA).
The case, Meyer v. United States (Docket No. 25-1535), involves a group of correctional officers who claim they perform essential duties related to maintaining safety and security at the prison, which they argue should qualify for overtime compensation. The court's decision to deny the government's motion to dismiss the plaintiffs' claims indicates that these activities may be considered integral to their principal work duties.
The plaintiffs in this case are current and former correctional officers employed by the U.S. Department of Justice at FCI Mendota. They allege that their primary responsibility is to maintain the safety and security of the institution, which requires them to perform certain tasks before and after their scheduled shifts. The officers claim they routinely work unpaid time, ranging from 15 to 30 minutes, during which they clear security screenings and perform other essential duties.
The dispute reached the Court of Federal Claims after the plaintiffs filed their initial complaint in September 2025. Following a motion to partially dismiss the complaint by the government in January 2026, the court held oral arguments in May 2026. The plaintiffs assert that the time spent clearing security screenings and passing through a sally port is integral to their work and thus compensable under the FLSA.
In its ruling, the court found that the plaintiffs had provided sufficient evidence to support their claims. Judge Eleni M. Roumel stated, "Plaintiffs have plausibly alleged sufficient facts to withstand a motion to dismiss." The court emphasized that the time spent undergoing security screenings is not merely a preliminary activity but is integral to the officers' principal duties. The ruling also highlighted that the plaintiffs' activities while in the security screening area, such as monitoring for contraband and interacting with inmates, contribute to their primary responsibilities.
The court also addressed the government's argument that the security screenings are not compensable under the FLSA because they are not principal activities. The court rejected this notion, stating that the activities performed during the screenings are essential to the officers' roles. The ruling further clarified that the continuous workday doctrine applies, meaning that all time spent on activities related to their principal duties is compensable.
The impact of this decision is significant for correctional officers at FCI Mendota and potentially other federal correctional facilities. It sets a precedent for how pre-shift and post-shift activities are treated under the FLSA, particularly for employees whose work involves maintaining safety and security in high-risk environments. The ruling may encourage other correctional officers to pursue similar claims for unpaid overtime.
Moving forward, the government has the option to appeal this ruling, although details regarding any potential appeal were not available in the court filing. The case may also lead to further litigation as the plaintiffs seek backpay and damages for the unpaid overtime they allege they are owed.