Chagoya v. Bartlett

Dist. Ct. did not err in granting defendant-City's motion for summary judgment in action filed by plaintiffs-members of police department's SWAT unit, alleging that defendant's failure to pay them for 15-minutes of off-duty time spent loading and unloading SWAT equipment to and from their residences violated Fair Labor Standards Act (FSLA), where such actions allowed them to respond more quickly to situations needing their services. Dist. Ct. properly found that activity of transporting, loading and unloading said equipment was not integral and indispensable to plaintiffs' principal activities as SWAT members, and thus failure to pay plaintiffs for time performing said off-duty activities did not violate FSLA. Also, Dist. Ct. did not err in granting summary judgment in favor of defendant in plaintiffs' Illinois Wage Payment and Collection Act claim, where record did not support existence of either formal or implicit agreement that defendant would pay plaintiffs for time spent transporting SWAT equipment to and from their residences.