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Drivers are entitled to compensation for sleeper berth time exceeding eight hours

On December 12, a panel from the First Circuit Court of Appeals issued a ruling regarding a case addressing sleeper berth time for team drivers and its corresponding compensation. The class-action lawsuit, filed in 2016 against CRST International and CRST Expedited, focused on the dispute over who benefits more from sleeper berth time during team driver operations: the employer or the employee.

The lawsuit stems from CRST’s training program, connecting trainee drivers with experienced ones. As is typical in team driving operations, CRST drivers spend their mandatory 10 hours off-duty time in the sleeper berth after reaching 14 hours of on-duty time.

The plaintiffs argue that the time drivers spend in the sleeper berth primarily benefits the employer, as drivers are confined in that restrictive environment. Additionally, they contend that the goal of team drivers is to keep the truck moving during rest periods, contributing to increased profits for the company. The First Circuit Court of Appeals supported the plaintiffs’ position regarding confinement.

En la imagen se observa una mujer durmiendo en la cabina de un camión

The court also considered the fact that team drivers travel during sleeper berth time, suggesting that this time is in CRST’s benefit. The First Circuit notes that the driving partner can call the resting partner for emergency assistance, even during the mandatory 10-hour off-duty period.

The sleeper berth compensation case revolves around two Department of Labor regulations:

1. Section 785.41 states that any work performed while traveling must be counted as hours worked unless sleeping is allowed in facilities provided by the employer.

2. Section 785.22 questions CRST’s interpretation of Section 785.41, pointing out that it would allow employers to avoid compensating drivers by confining them to the sleeper berth, even for an unreasonable amount of time.

Both the district and appeals courts concluded that both regulations should be considered together. Consequently, they determined that in team driver operations, drivers are entitled to compensation for sleeper berth time exceeding eight hours.


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