BAYTOS v. United States

CourtUnited States Court of Federal Claims
DecidedFebruary 27, 2025
Docket21-1085
StatusPublished

This text of BAYTOS v. United States (BAYTOS v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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BAYTOS v. United States, (uscfc 2025).

Opinion

In the United States Court of Federal Claims No. 21-1085 Filed: January 31, 2025 1 Re-issued: February 27, 2025 ________________________________________ ) RAYMOND BAYTOS, et al., ) ) Plaintiffs, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ) ________________________________________ )

OPINION AND ORDER

MEYERS, Judge

This is one of a series of cases brought by correctional officers seeking overtime pay for tasks they must complete prior to and after leaving their assigned posts at a federal prison. Generally, employees are only entitled to overtime compensation for preliminary or postliminary activities—those before and after the employee’s primary job duties—unless those activities are indispensable to the performance of those primary job duties. But here the issue is not so much whether activities for which the Plaintiffs claim entitlement to overtime pay are indispensable to their primary job duties; the issue here is much more whether the Plaintiffs are, in fact, performing their primary job duties during this time—i.e. functioning as correctional officers. Because the Parties dispute all but the most basic facts, the court denies the Plaintiffs’ motion for partial summary judgment and denies all but a small piece of the Government’s cross-motion for partial summary judgment. The majority of the issues in this case must be resolved after trial.

I. Background

The Plaintiffs are 146 current and former correctional officers (“COs”) employed by the United States Bureau of Prisons (“BOP”) at the Federal Correctional Institution (“FCI”) and/or Federal Satellite Low Security (“FSL”) Elkton in Lisbon, Ohio (collectively, “the Institution”). ECF No. 11 ¶¶ 1, 4. They filed this collective action alleging the Government has required them

1 The court initially filed this Opinion and Order under seal to allow the Parties to propose redactions. Because the Parties informed the court that no redactions are necessary, the court re- issues this Opinion and Order in full. to work more than 8 hours per day without overtime pay in violation of the Fair Labor Standards Act (“FLSA”) of 1938, 29 U.S.C. §§ 201 et seq. ECF No. 11 ¶ 1. Specifically, the Plaintiffs allege that the Government failed to compensate them with the overtime the FLSA requires for certain pre-shift and post-shift activities performed beyond their regularly scheduled 8-hour days and 40-hour workweeks. Id. ¶ 7. They seek relief under the FLSA and under the Back Pay Act (BPA), 5 U.S.C. § 5596, for backpay, liquidated damages plus interest, and reasonable attorney’s fees. Id. at 19.

The Institution is a low security prison facility that houses between 1,400 and 1,800 inmates at any given time. ECF No. 38-9 at 32:3–9. COs are assigned to work 8-hour shifts at correctional posts within the Institution, which is staffed 24-hours per day, 365 days per year. Id. at 28:6–9. The 24-hour posts 2 have three scheduled shifts: the Morning Watch, from 12 a.m. to 8 a.m.; the Day Watch, from 8 a.m. to 4 p.m.; and the Evening Watch, from 4 p.m. to 12 a.m. Id. at 81:1–12. The posts involved in this case are Compound #1, Compound #2, Control Center #1, the Housing Units, and the Special Housing Unit #1 (the “SHU”). ECF No. 38 at 5, ¶ 12.

COs have a series of steps to take before getting to their posts. Because they must be at their posts before their scheduled start time, they necessarily must arrive at the Institution before then. The Parties dispute what each step requires, how long they take, and whether they are compensable.

The basic facts about what COs do before getting to assigned posts are not generally in dispute. Upon entering the Institution, the COs must first pass through a security screening. ECF No. 43 at 5, ¶ 25. This involves passing through a magnetometer and placing all personal items on a conveyor for an x-ray search.

Once cleared, the COs generally don certain equipment they brought into the Institution with them that they claim they could not wear through the magnetometer. ECF No. 38 at 9, ¶ 36. Here there is some dispute as to whether the COs could wear their equipment through the magnetometer and whether the COs must don their equipment as soon as they clear or whether they can carry it with them to their assigned post. The parties also dispute whether the duty belts that the Plaintiffs pass through the x-ray machine constitute specialized equipment.

From here, the path a CO takes depends on where he or she is assigned to work for a given shift. COs assigned to the Control Center go straight there. ECF No. 38-10 at 130:9–16. COs working inside the secure compound of the Institution proceed through a sally port. ECF No. 43 at 34, 40. The sally port consists of a door that lets the COs into a corridor that has a door into the prison on the other end, and only one of these two doors may be open at a time. Inside the sally port is an accountability board on which they place an accountability chit—an identification tag—to let the command center know that they are inside the secure facility. ECF No. 38-10 at 123:10–20.

Once they clear the sally port, the COs proceed to walk to the Compound and pass through the “Kong Gate”—a large gate in a security wall/fence that separates the inmates inside

2 There are posts at the Institution that are staffed for 8 or 16 hours per day, but those are not at issue in this litigation. the Institution. ECF No. 38 at 11, ¶ 44; ECF No. 43 at 41–43. As discussed below, there is some dispute as to whether and how COs encounter inmates in this area between the sally port and the Kong Gate. After passing through the Kong Gate, the COs are in the Compound with the inmates. ECF No. 38 at 11, ¶ 45; ECF No. 43 at 46.

Next, COs walk to their assigned posts within the Compound. ECF No. 38 at 11; ECF No. 43 at 43. Recall that the assigned posts at issue from here are Compound #1, Compound #2, the Housing Units, and the SHU. ECF No. 38 at 5, ¶ 12. At the assigned posts, the oncoming COs relieve the officers that are going off-duty. ECF No. 38-9 at 73:2–17. The incoming and outgoing officers conduct an information exchange and an equipment exchange, although the parties dispute whether both are required. Id.; ECF No. 43 at 12, ¶ 56.

The tasks are repeated at the end of a shift: The outgoing officer engages in an information and equipment exchange with the incoming officer, and walks to and passes through the Kong Gate and into the sally port. In the sally port, the CO flips his or her accountability chit, informing the Command Center that the CO is no longer on the Compound. ECF No. 38 at 16, ¶¶ 68–69; ECF No. 43 at 15, ¶ 69. The CO then exits the sally port and the Institution. Id. The parties dispute several of the facts relevant to determining whether activities are compensable as well as how much time it takes to complete each step. See generally ECF No. 43 at 3–15, ¶¶ 1–66.

The parties cross-move for partial summary judgment.

II. Legal Standard

“The Court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” RCFC 56(a). A dispute about a material fact is genuine if the evidence would permit a reasonable jury to return a verdict in favor of the non-movant. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247–48 (1986). A fact is material if it “might affect the outcome of the suit under the governing law[,]” as opposed to “disputes that are irrelevant or unnecessary[.]” Id.

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BAYTOS v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baytos-v-united-states-uscfc-2025.