No Meal Break Violation Where Employees Are Incentivized to Stay Onsite Through Offer of Discounted Meal
Today, the Ninth Circuit issued its opinion in Rodriguez v. Taco Bell Corp., upholding the district court’s grant of summary judgment in favor of Taco Bell on class claims for alleged meal break violations. In this case, Taco Bell authorized and permitted employees to take meal breaks during which they were relieved of duty and free to leave the premises. However, Taco Bell offered employees the option of purchasing a discounted meal at Taco Bell, in which case they had to remain on site to eat it (in order to prevent theft/abuse associated with employees bringing discounted food to third parties outside the restaurant). Because no good deed ever goes unpunished in California, a class action lawsuit was filed against Taco Bell alleging that their practices violated California law by denying employees lawful meal breaks.
Thankfully, the courts seem to have actually got this one right, finding the plaintiffs’ claim to be without merit and undeserving of a trial. The plaintiffs had argued that time spent eating discounted meals in the restaurant had to be compensated as work time because they purportedly were subject to Taco Bell’s “control” during this time by virtue of not being allowed to leave the premises. The Ninth Circuit flatly rejected this argument, appropriately reasoning that the choice to purchase a discounted meal was purely voluntary (and optional) on the part of employees. If they didn’t wish to remain on the premises for a meal break, they simply could have chosen not to purchase a discounted meal, in which case they would have been free to leave the premises for their meal break.
This seems like a no-brainer, right? If only Taco Bell could recover all of its fees incurred to defend this shakedown claim.