Auto-deduction cases involve a potential class of employees who allege that they were not paid for time worked because their employer automatically deducted time for meal breaks. The employees claim that, for various reasons, they were not able to take their breaks and, therefore, are owed for the time that was deducted from their hours worked. These claims have been on the rise in the past few years but, recently, have seen rougher times as more and more courts have refused to certify the class.
A recent decision from the District of Massachusetts is another case to add to that list. In Raposo v. Garelick Farms, LLC, a group of truck drivers sought back pay for time worked during meal breaks that were automatically deducted from their pay. The court denied the plaintiff-employees’ motion for class certification, though, concluding that the employees had failed to meet their burden of proof.
The court’s analysis was simple but solid, looking to two issues. First, did the employees show that everyone in the class had worked through their breaks and, if so, did they do so for the same reason? Second, could the employees’ damages be calculated on a class-wide basis? The court answered both questions in the negative.