Maryland: De Minimis Doctrine Applies to State Wage and Hour Laws
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APPLIES TO All Employers with Employees in MD |
EFFECTIVE July 3, 2025 |
QUESTIONS? Contact HR On-Call |
Quick Look
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Discussion
In Martinez v. Amazon.com Services LLC, the Maryland Supreme Court held that the de minimis doctrine applies to claims brought under the state’s wage and hour laws. The de minimis doctrine allows employers to disregard “insignificant” amounts of time spent on work-related tasks when calculating an employee’s compensable working hours.
The case was brought by a former Amazon employee who worked at the Baltimore fulfillment center and filed a class-action lawsuit in 2021 seeking unpaid wages for time spent going through security checks after clocking out. As part of the suit, the plaintiff alleged that she and other employees spent anywhere from 3 to 15 minutes participating in these security checks. Amazon argued that they did not owe employees compensation for this time because it fell under the purview of de minimis time. The plaintiff argued that the de minimis rule contradicts Maryland’s public policy of ensuring workers are paid for all work performed. Ultimately, the issue of whether or not state law recognizes the principle of de minimis time is what proceeded to the Maryland Supreme Court.
Ultimately, the court determined that the de minimis doctrine is a long-standing common-law principle that Maryland legislators would have been aware of when initially enacting the state’s wage statutes. The Court concluded that, absent a clear rejection from the General Assembly, the doctrine applies by default. According to the Court, Maryland’s wage laws are not intended to hold employers liable for negligible amounts of unrecorded time, citing the need to balance enforcement with practical workplace realities. Importantly, the court did not address whether the specific time spent by the class action employees actually constituted de minimis time. Instead, the court only addressed whether the de minimis doctrine was recognized in Maryland. The matter was therefore sent back to the lower courts to determine whether the security check time was compensable or excludable under the de minimis doctrine.
This decision provides some clarity and relief for Maryland employers; however, the ruling does not give employers a free pass. Employees may still argue that time spent under employer control is not de minimis, especially when aggregated across shifts or among large workforces. Despite the Court’s conclusion, the plaintiffs will be permitted to pursue their claims if they can show the time lost was substantial enough to warrant compensation under the doctrine’s parameters. The threshold for what counts as de minimis is also not clearly defined by the court’s decision, so employers should continue to monitor future legal developments.
Action Items
- Review employer timekeeping practices for compliance.
- Have appropriate personnel trained on timekeeping practices.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2025 ManagEase