The Connecticut Supreme Court Holds That The FLSA Preempts State Travel Time Law

In Sarrazin v. Coastal, Inc., 311 Conn. 581 (2014), the Connecticut Supreme Court analyzed when an employee's travel time between home and work constitutes compensable work time. The Court affirmed the decision of the trial court in holding that a plumber who carried company tools in a company vehicle during his daily commute to his jobsite and home was not entitled to compensation for that travel time. He was, however, entitled to overtime compensation for the after-hours time he spent picking up tools or equipment from the company's warehouse.

Factual Background

The plaintiff was a plumber whose work involved travel from his home to a designated jobsite, which would change occasionally. His daily round-trip travel time was approximately two hours. During his employment, the plaintiff was promoted to foreman and at that point he was provided with a company vehicle for his daily commute to the jobsite.

The plaintiff had to keep some of the employer's tools and equipment in the vehicle to bring back and forth from his home to the jobsite. Occasionally after regular working hours, the plaintiff had to pick up tools and equipment from the company warehouse.

The plaintiff drove the company vehicle until it was totaled in an accident. He then drove his own truck for a period of about eight or nine months until the company provided him with another vehicle. The employer paid him an extra $50 per week to drive his own truck.

The plaintiff was eventually demoted and no longer entitled to drive a company vehicle for his daily commute.

The Plaintiff's Claims and the Trial Court Case

The plaintiff claimed he was entitled to overtime wages for the daily commute between his home and the jobsite and the after-hours trips to the warehouse to pick up tools and equipment. The plaintiff also claimed he was entitled to compensation for cleaning the vehicles (whether his own vehicle or the company vehicle) and organizing the tools after he arrived home each day.

Following a bench trial, the trial court found the employer liable only for payment of overtime compensation for the plaintiff's after-hours trips to the warehouse. The trial court held that the plaintiff was entitled to recover overtime compensation by way of damages for those trips in the amount of $641.44.

The Appeal

On appeal the plaintiff claimed the trial court incorrectly held that the FLSA preempts Connecticut law governing overtime wages and travel time, and that it improperly applied...