Danilo Silva’s Perspective on Recent Legal Developments
January 3, 2024
In a landmark decision last December, the First Circuit Court of Appeals decreed that truck drivers must be compensated for time spent in sleeper berths beyond eight hours. This ruling, emerging from a case against CRST Expedited and CRST International, marks a significant shift in how driver hours are accounted for under the Fair Labor Standards Act (FLSA).
The controversy began with a 2016 lawsuit led by Juan Carlos Montoya and fellow former trainees of CRST, challenging the company’s pay practices as contrary to the FLSA. The central question was whether sleeper berth hours exceeding eight hours in a 24-hour period should be compensated.
CRST’s unique team-based training approach, allowing continuous operation of vehicles while adhering to Department of Transportation (DOT) regulations, came under scrutiny. While in the sleeper berth, drivers can engage in various personal activities, yet the court had to decide if this time benefited the employer, thus warranting compensation.
CRST’s compensation model is based on the total miles assigned to a team, divided among the drivers according to experience. Notably, the company did not include sleeper berth time in calculating hourly wages, potentially resulting in wages below the FLSA’s minimum requirement.
Montoya and his colleagues contended that non-compensation for sleeper berth time exceeding the eight-hour exclusion under DOL regulations resulted in sub-minimum hourly wages. The U.S. District Court for Massachusetts initially ruled in favor of the drivers, a decision upheld by the appeals court.
The key legal question was whether the time spent in sleeper berths primarily benefitted the employer. Factors like the driver’s location and ability to engage in personal activities were considered. The court found that the confined and limited nature of the sleeper berth, coupled with the continuous movement of the truck, predominantly benefitted CRST.
CRST’s argument that DOT regulations should dictate FLSA applicability was rejected. The court emphasized the distinct focus of DOT regulations on safety, not on worker compensation.
In conclusion, the appeals court ruled in favor of Montoya, establishing that time spent in the sleeper berth beyond eight hours constitutes compensable work under the FLSA. This ruling reshapes the compensation landscape in the trucking industry and underscores the need for compliance with labor standards.
For truck company owners like Danilo Silva, this ruling highlights the evolving nature of labor regulations in the industry. It underscores the importance of staying abreast of legal developments to ensure fair and lawful treatment of drivers, a crucial asset to the logistical backbone of our economy.