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Tuesday, August 19, 2025

MD Supreme Court rules de minimis doctrine applies to claims under wage and hour laws - Maryland Daily Record

The Maryland Supreme Court on Thursday held the de minimis doctrine applies to claims brought under the state’s wage and hour laws, delivering a slight setback to Amazon workers in their class-action lawsuit against the company over unpaid wages for time spent waiting to undergo and undergoing mandatory security screenings at a fulfillment center.

In a 5-2 decision with Justice Jonathan Biran writing for the majority, the Maryland Supreme Court held the de minimis doctrine, which allows courts to decline to rule on insignificant matters, applies to claims brought under the Maryland Wage Payment Collection Law and the Maryland Wage and Hour Law.

The question came to the high court by way of the U.S. District Court for the District of Maryland, which certified the question of law to the justices.

Estefany Martinez, a former Amazon employee who worked at the Baltimore fulfillment center from June 2017 through November 2021, filed a class-action lawsuit in December 2021 to recover unpaid wages for time spent waiting to undergo security screenings after clocking out, ranging from three minutes or less in waiting time to 15 minutes or more.

Martinez argued the Maryland General Assembly has not adopted or incorporated the de minimis doctrine into the Maryland wage laws, and further that the de minimis rule contradicts the public policy underlying the Maryland Wage and Hour Law by requiring workers to absorb the cost of otherwise compensable work. Amazon, meanwhile, argued the de...



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