The Pennsylvania Supreme Court's July 21 decision in In re Amazon.com, 255 A.3d 191 (Pa. 2021) significantly expanded what is considered compensable time under the Pennsylvania Minimum Wage Act (PMWA). In the 5-2 decision, the commonwealth's highest court both broadly defined "hours worked" within the meaning of the PMWA and flatly rejected the application of any de minimis exception.

Amazon employees Neal Heimbach and Karen Salasky brought a putative class action against Amazon to recover wages for time spent in post-shift security screenings pursuant to the PMWA. For clarity purposes, the case will be referred to as Heimbach. The case was removed to federal court and transferred to the U.S. District Court of Kentucky by the U.S. Judicial Panel on Multidistrict Litigation. The case involved two certified questions of law from the U.S. Court of Appeals for the Sixth Circuit to the Pennsylvania Supreme Court, namely: whether time spent on an employer's premises waiting to undergo, and undergoing mandatory security screenings was compensable as "hours worked" within the meaning of the PMWA; and whether the doctrine of de minimis non curat lex applied to bar such claims.