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Keywords

damagesattorneystatuteappealtrialliquidated damages
damagesattorneystatuteappealliquidated damages

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Skidmore v. Swift & Co. U.S.

Facts

Seven employees of the Swift and Company packing plant at Fort Worth, Texas, brought an action under the Fair Labor Standards Act to recover overtime, liquidated damages, and attorneys' fees, totaling approximately $77,000. The employees were engaged in general fire-hall duties and maintenance of firefighting equipment during the day and agreed to stay on the employer's premises or within hailing distance three to four nights a week, primarily to respond to fire alarms. The district court ruled that the time spent waiting to respond to alarms did not constitute hours worked, which was affirmed on appeal.

Seven employees of the Swift and Company packing plant at Fort Worth, Texas, brought an action under the Fair Labor Standards Act to recover overtime, liquidated damages, and attorneys' fees, totaling approximately $77,000. The employees were engaged in general fire-hall duties and maintenance of firefighting equipment during the day and agreed to stay on the employer's premises or within hailing distance three to four nights a week, primarily to respond to fire alarms.

Issue

Whether the time the employees spent waiting to respond to fire alarms constituted hours worked under the Fair Labor Standards Act.

Whether the time the employees spent waiting to respond to fire alarms constituted hours worked under the Fair Labor Standards Act.

Rule

No principle of law found either in the statute or in Court decisions precludes waiting time from also being working time. Whether such time falls within or without the Act is a question of fact to be resolved by appropriate findings of the trial court.

No principle of law found either in the statute or in Court decisions precludes waiting time from also being working time.

Analysis

The Supreme Court held that the determination of whether waiting time constitutes working time is a factual question that must consider the agreements between the parties and the surrounding circumstances. The Court noted that the trial court's conclusion that waiting time does not constitute work was erroneous, as it did not adequately consider the nature of the employees' duties and the context of their waiting time.

The Supreme Court held that the determination of whether waiting time constitutes working time is a factual question that must consider the agreements between the parties and the surrounding circumstances.

Conclusion

The Court reversed the judgment of the court of appeals and remanded the case for further proceedings.

The Court reversed the judgment of the court of appeals and remanded the case for further proceedings.

Who won?

The petitioner employees prevailed in the case because the Supreme Court found that the lower courts had erred in their interpretation of the law regarding waiting time and working time.

The petitioner employees prevailed in the case because the Supreme Court found that the lower courts had erred in their interpretation of the law regarding waiting time and working time.

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