A federal court has ruled in favor of correctional officers at the Federal Correctional Institution Fort Dix, allowing them to seek compensation for unpaid wages related to pre- and post-shift activities under the Fair Labor Standards Act (FLSA). The decision affects how federal employees, particularly correctional officers, are compensated for time spent on mandatory security screenings and other preparatory tasks before and after their shifts.
The case, Moore v. United States, was filed in the United States Court of Federal Claims (docket number 25-1461) and centers on the claims of correctional officers who argue that they should be compensated for time spent undergoing security screenings and walking through a controlled entrance known as a sally port. The ruling is significant as it clarifies the interpretation of the FLSA regarding what constitutes compensable work for federal employees.
Background
The plaintiffs in this case are correctional officers employed at FCI Fort Dix, a low-security prison in New Jersey housing over 4,000 inmates. They filed their complaint on September 2, 2025, seeking compensation for time spent on activities they argue are essential to their roles, including security screenings, donning equipment, and walking to their posts. The officers claim that these activities add up to at least 15-30 minutes of uncompensated work per shift.
The government responded by filing a partial motion to dismiss the case, arguing that the officers are not entitled to compensation for the time spent undergoing security screenings and passing through the sally port, as these activities are not considered principal activities under the FLSA. The government did not contest the compensation claims related to other pre-shift activities, such as donning duty belts and exchanging information with outgoing officers.
The Ruling
Judge Kathryn C. Davis ruled against the government's motion to dismiss, stating that the plaintiffs had adequately stated a claim for compensation under the FLSA. The court found that while undergoing security screenings is not a principal activity itself, it is integral and indispensable to the officers' principal activities of maintaining safety and security within the institution.
The court ruled, "Plaintiffs have plausibly alleged entitlement to compensation for this time as well, since employers are required to compensate their employees for all walking time that falls between the employees’ first principal activity and last principal activity of the workday."
Additionally, the court noted that the continuous workday rule applies to federal employees, meaning that all time between the start of the first compensable activity and the end of the last compensable activity must be compensated. This ruling allows the officers to claim compensation for time spent passing through the sally port and flipping their accountability chit, as these activities occur after they don their duty belts, which is recognized as a compensable activity.
Impact
This ruling has significant implications for federal correctional officers and potentially other federal employees who perform similar pre- and post-shift activities. It clarifies that activities essential to the safety and security of federal institutions may be considered compensable under the FLSA, even if they are not the principal activities for which employees were hired. The decision aligns with previous rulings in similar cases, reinforcing the notion that security screenings and related activities are integral to the work of correctional officers.
Moreover, the ruling may set a precedent for future cases involving federal employees seeking compensation for time spent on mandatory security measures and other preparatory work. It emphasizes the importance of ensuring that employees are fairly compensated for all time worked, particularly in high-security environments where safety is paramount.
What's Next
The government has the option to appeal the ruling, but as of now, the case will proceed, allowing the plaintiffs to seek compensation for their claims. This ruling may also prompt other federal employees in similar situations to consider filing claims for unpaid wages related to their pre- and post-shift activities.