Employees who were required to carry work documents while commuting to their worksite do not have to be compensated for this time under the Fair Labor Standards Act, the Second Circuit holds.

The case involved field inspectors who were required to carry assigned documents weighing between 15 and 20 pounds from the time they picked them up on a Friday morning until the time they returned them the following Friday. The inspectors were required to report directly to inspection sites from their homes, and take the materials home with them at the end of the workday. The inspectors claimed that carrying the documents lengthened their commute between 10 to 30 minutes.

The Court says that in the particular circumstances of this case, “the mere carrying of inspection documents without any other active employment-related responsibilities while commuting is not work under the FLSA, except to the extent that it increases the duration of the commute. The record shows that any increase of commuting time in this case is de minimis as a matter of law and thus not compensable under the FLSA.” Singh v. New York City