In a landmark decision reshaping norms in the trucking industry, the U.S. Appeals Court has ruled that truckers must be compensated for sleeper berth time exceeding eight hours, aligning with federal labor law. On December 12, 2023, the United States Court of Appeals for the First Circuit ruled in favor of a group of truckers led by Juan Carlos Montoya in their legal battle against CRST Expedited and CRST International.
The core of the dispute was whether the time spent by truckers in the sleeper berth beyond eight hours in a 24-hour period should be compensable. The truckers, spearheaded by Montoya, argued that CRST’s failure to pay for this time violated the Fair Labor Standards Act (FLSA). They contended that for team truckers, who alternate between driving and resting, the sleeper berth time should be considered as “on duty” and thus compensated, to prevent their wages from dropping below the minimum wage.
The court shed light on CRST’s business model, which benefits from drivers being confined to the sleeper berth beyond their eight-hour sleep period. This model, enabling near-continuous truck movement while adhering to Department of Transportation (DOT) regulations on driving hours, greatly benefits CRST. The court emphasized the intrinsic value of sleeper berth time to CRST’s operations, enabling deliveries to be completed in roughly half the time it would take a solo driver.
Additionally, the court recognized the limitations of sleeper berth time. Despite CRST’s argument that this time was primarily for drivers’ benefit, allowing personal activities, the court recognized the severe limitations imposed by the physical confines of the sleeper berth in a moving truck. The court understood that the drivers’ time in the sleeper berth was not entirely their own, contrary to CRST’s claims.
Lastly, the court took into account the impact of sleeper berth time on drivers. It was noted that the nature of team driving could require the resting driver to provide emergency assistance during their rest period. This, combined with the discomfort of the sleeper berth, led to the conclusion that sleeper berth time was more than a minimal burden on drivers and predominantly benefited the employer. Ultimately, the court’s decision was clear: “Time spent in the sleeper berth exceeding eight hours per day is compensable work under the FLSA.” This ruling represents a significant victory for truckers, recognizing the true demands and constraints of their work environment.
