In Estefany Martinez v. Amazon.com Services LLC, the Supreme Court of Maryland upheld the use of the de minimis doctrine in wage and hour disputes. The de minimis doctrine analyzes whether small fractions of time are compensable under wage and labor laws. See Anderson v. Mt. Clemens Pottery Company, 328 U.S. 680 (1946). In Martinez, it was argued that the General Assembly intended for the de minimis doctrine to be incorporated into Maryland’s wage laws. The counterparty took the position that doing so contradicts the underlying public policy reasons behind the Maryland Wage and Hour Law (MWHL) and the Maryland Wage Payment and Collection Law (MWPCL) (hereinafter collectively referred to as the “Maryland Wage Laws”).
In a 5-2 decision, the Supreme Court of Maryland analyzed case law, regulations, and other authority surrounding the Fair Labor Standards Act of 1938 (FLSA), as Maryland often looks to the interpretation of Federal employment statutes and precedent for guidance. Additionally, the Court analyzed the relevant legislative history and how the Maryland General Assembly has traditionally acted when deciding whether to integrate Federal regulations into its corresponding State regulations. The Court noted, for example, that when the FLSA adopted the Portal-to-Portal Act (PPA), the Maryland General Assembly limited state legislation to purposefully exclude the PPA from the Maryland Wage Laws. The Court found this to be persuasive, as the General Assembly took affirmative steps to exclude certain components of the Federal regulation. In contrast, the Court in Martinez explained that the General Assembly took no such affirmative steps to exclude the de minimis doctrine. Therefore, the Court concluded that the General Assembly intended for the de minimis doctrine to be applicable to the Maryland Wage Laws.
It is imperative that practitioners, and any business operating within the State, stay abreast of the everchanging employment laws, both at the Federal and State level. Eccleston and Wolf has experience in all areas of employment law and related litigation, including:
- Wrongful discharge;
- Discrimination claims under local, State, and Federal statutes;
- Wage and overtime actions;
- Civil rights claims; and
- Other common law and statutory employment matters.
Eccleston and Wolf attorneys regularly provide such representation in local, State and Federal administrative agencies and courts. If you have an employment-related legal issue or dispute, please contact the Firm’s Managing Principal, Stephen Cornelius (Click Here for a direct link via email).