Does California pay for a few minutes of off-the-clock work?

The employee clocked out on a store computer, then transmitted the daily sales data, set the alarm, locked the door, and sometimes walked colleagues to their cars. It came to roughly four to ten minutes a night, every night.

Under federal law, employers had long relied on the de minimis doctrine to disregard small, hard-to-record amounts of time. The California court held that neither the state's wage statutes nor its wage orders had adopted that doctrine, and refused to read it in for work that is regular and readily capturable.

The court was explicit that modern timekeeping matters to the analysis. Work that was genuinely impractical to record in 1946 is often trivially recordable now, and an employer who could capture the time but chose not to is in a weak position.

The court left open whether some truly irregular or fleeting activity might still be disregarded. That is a narrow opening, and it is not where a routine closing procedure sits.