COURTS

Companies could be on the hook for work-related activities before and after shifts start, court rules

3d ago · March 23, 2026 · 3 min read

Why It Matters

An Illinois Supreme Court ruling could significantly expand wage obligations for employers across the state by requiring compensation for work-related activities that occur before and after scheduled shifts. The decision clarifies that Illinois wage law does not incorporate federal exclusions that would otherwise shield companies from paying employees for these preparatory and concluding tasks. The ruling has immediate implications for how employers in Illinois structure compensation practices and could affect thousands of workers in warehousing, retail, manufacturing, and other industries where pre- and post-shift protocols are standard practice.

What Happened

The Illinois Supreme Court ruled that state wage law does not include certain federal exclusions that would protect companies from compensating employees for work-related activities occurring outside their scheduled shifts. The decision stems from a civil lawsuit brought by two former Amazon employees who were not paid for mandatory pre-shift health screenings conducted during the COVID-19 pandemic.

The case centers on whether Illinois employers must compensate workers for time spent on required activities before clocking in or after clocking out. Amazon argued that the court should apply federal regulations that exclude certain preparatory activities from compensation requirements. The former employees countered that Illinois state law contains no such exemptions and therefore entitles them to payment for the health screening time.

The Illinois Supreme Court sided with the employees, determining that state wage law does not defer to federal exclusions in this context. The ruling establishes that Illinois employers cannot rely on federal regulatory frameworks to avoid compensating workers for mandated pre- and post-shift duties. The case will now return to the U.S. Court of Appeals for the Seventh Circuit for further proceedings.

By the Numbers

The decision affects wage compensation standards across Illinois, though specific damage amounts from this case were not disclosed in the ruling. The case originated as a civil suit brought by two former Amazon employees, establishing the precedent through an individual dispute rather than class action litigation. The Seventh Circuit will now review the Illinois Supreme Court’s interpretation of state wage law. The ruling applies to all employers operating in Illinois regardless of company size or industry sector. Pre- and post-shift activities that commonly fall under this requirement include mandatory health screenings, security checks, equipment setup, and other job-related tasks performed outside compensated work time.

Zoom Out

Illinois joins other states that have taken expansive approaches to wage compensation by requiring payment for work-related activities outside traditional shift hours. The decision reflects a broader national trend of state courts and legislatures narrowing employer exemptions related to wage and hour requirements. Several states, including California and New York, have issued similar rulings or implemented stricter wage laws that require compensation for preparatory work time.

The ruling also reflects ongoing tensions between federal and state wage standards. While federal law under the Fair Labor Standards Act provides certain exemptions for preparatory activities, states retain authority to impose stricter requirements on employers operating within their borders. This decision clarifies that Illinois has chosen the stricter path by not incorporating federal exclusions into its state wage law framework.

The case gained prominence amid heightened scrutiny of warehouse and logistics company labor practices. Amazon and similar large employers have faced multiple legal challenges across different states regarding compensation for security screening, package checks, and other mandatory activities. This Illinois decision could influence similar disputes pending in federal court.

What’s Next

The case returns to the U.S. Court of Appeals for the Seventh Circuit, which covers Illinois, Indiana, and Wisconsin. The appellate court will review the Illinois Supreme Court’s interpretation of state wage law and may address whether federal law preempts the state ruling. A decision from the Seventh Circuit could clarify the interaction between state and federal wage requirements across the three-state region.

Illinois employers should review their current compensation practices for pre- and post-shift activities. Companies may need to adjust timekeeping systems, compensation structures, and workplace protocols to ensure compliance with the ruling. The decision could prompt regulatory guidance from the Illinois Department of Labor regarding acceptable practices for compensating preparatory and concluding work activities.

Additional litigation is likely to emerge as the ruling creates a clear legal standard for wage compensation in Illinois. Employees who were not compensated for pre- or post-shift work may pursue similar claims, and employers across industries will face pressure to reassess their wage practices to align with the court’s interpretation of state law.

Last updated: Mar 23, 2026 at 7:02 AM GMT+0000 · Sources available
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