Thomas Hootselle, Jr., individually and on behalf of all others similarly situated, and Missouri Corrections Officers Association v. Missouri Department of Corrections

CourtSupreme Court of Missouri
DecidedJune 1, 2021
DocketSC98252
StatusPublished

This text of Thomas Hootselle, Jr., individually and on behalf of all others similarly situated, and Missouri Corrections Officers Association v. Missouri Department of Corrections (Thomas Hootselle, Jr., individually and on behalf of all others similarly situated, and Missouri Corrections Officers Association v. Missouri Department of Corrections) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Thomas Hootselle, Jr., individually and on behalf of all others similarly situated, and Missouri Corrections Officers Association v. Missouri Department of Corrections, (Mo. 2021).

Opinion

SUPREME COURT OF MISSOURI en banc THOMAS HOOTSELLE, JR., et al., ) Opinion issued June 1, 2021 individually and on behalf of all others ) similarly situated, and MISSOURI ) CORRECTIONS OFFICERS ) ASSOCIATION, ) ) Respondents, ) v. ) No. SC98252 ) MISSOURI DEPARTMENT OF ) CORRECTIONS, ) ) Appellant. )

APPEAL FROM THE CIRCUIT COURT OF COLE COUNTY The Honorable Patricia S. Joyce, Judge

The Missouri Department of Corrections (“MDOC”) appeals a judgment of the Cole

County circuit court awarding a class of Missouri corrections officers approximately

$113 million plus post-judgment interest for breach of contract. On appeal, MDOC claims,

among other things, that the circuit court erred in determining MDOC is liable on the

corrections officers’ breach of contract claims for time spent performing all preshift and

postshift activities. The corrections officers’ statement of undisputed material facts in support

of their motion for partial summary judgment demonstrated, as a matter of law, that the

retrieval of keys and radios and the supervision of inmates while walking to and from the

corrections officers’ daily posts are integral and indispensable to their work as correction officers. Under the continuous workday rule, all preshift and postshift activities after the first

and before the last principal activity of either retrieving or returning keys and radios or

supervising inmates are also compensable. The undisputed material facts do not establish,

however, the chronological order of the preshift and postshift activities to permit a

determination of which preshift and post activities are compensable under the continuous

workday rule. Additionally, the undisputed facts are insufficient to show all the other preshift

and postshift activities are compensable as principal activities, as a matter of law, so the circuit

court’s determination that all preshift and postshift activities are compensable was erroneous.

The award of damages and the circuit court’s declaratory and injunctive relief were based on

that erroneous finding of liability, so those rulings are also erroneous.

The portion of the circuit court’s judgment determining MDOC must compensate the

corrections officers for time spent retrieving keys and radios and time spent monitoring and

supervising offenders while not on post is affirmed. The remainder of the circuit court’s

judgment is vacated, and the cause is remanded.

I. Factual and Procedural Background

The plaintiffs are a class of corrections officers employed by MDOC 1 and the

corrections officers’ collective bargaining unit, the Missouri Corrections Officers Association

(“MOCOA”). The class covers approximately 14,000 officers employed within 21

correctional facilities. MDOC employs the corrections officers to supervise, guard, escort,

1 The class is defined as all persons employed in positions as corrections officer I or corrections officer II by MDOC at any time from August 14, 2007, to the present date for claims relating to unpaid straight-time compensation and from August 14, 2010, to the present date for unpaid overtime compensation. 2 and discipline offenders incarcerated in Missouri prisons. Before arriving at their posts to

perform these duties, however, the corrections officers have long been required to perform a

variety of other tasks. These tasks are known within the MDOC as preshift activities.

As part of their preshift activities, the officers log their arrival, scan identification, sign

entry and exit records or submit to biometric identification, pass through security, report to a

supervisor, retrieve equipment, walk to their posts, and exchange information with other

corrections officers. Corrections officers execute these same tasks in reverse upon leaving

their posts. When performed after leaving a post, these activities are referred to as postshift

activities. MDOC has never paid officers for time spent performing preshift and postshift

activities and has consistently denied requests for overtime pay for time spent completing

these activities.

In 2007 and 2014, the corrections officers, through MOCOA, entered into labor

agreements with MDOC. The labor agreements govern a wide array of corrections officers’

rights and duties as MDOC employees and the agreements incorporated MDOC’s procedure

manual’s definitions and terminology. The manual defines how state compensatory time and

federal overtime are earned by corrections officers. Together, the agreement and the manual

provide that MDOC will comply with the Fair Labor Standards Act of 1938 (FLSA) regarding

the accrual and payment of overtime. The procedure manual also states its purpose is to

ensure departmental compliance with the FLSA and that the corrections officers must be

compensated for “time worked.”

3 In 2012, the corrections officers filed a class action lawsuit, 2 alleging MDOC breached

its statutory obligations under the FLSA and its contractual duties under the labor agreements

to pay the corrections officers for preshift and postshift activities. As amended, 3 the

corrections officers’ petition contains seven counts. Counts I and II asserted freestanding

claims for violations of section 105.935.3, RSMo Supp. 2005, and the FLSA, respectively.

Count III alleged MDOC breached a contract created by operation of section 105.935.3,

RSMo Supp. 2005, and 1 C.S.R. 20-5.010(1)(E) by failing to pay the corrections officers for

preshift and postshift activities. 4 Counts IV and V alleged claims for damages under unjust

enrichment and quantum meruit theories, respectively. In Count VI, MOCOA alleged MDOC

breached the 2007 and 2014 labor agreements by failing to pay the corrections officers for

preshift and postshift activities under the FLSA. In the alternative to Count VI, MOCOA

sought a declaration in Count VII that MDOC was contractually obligated to compensate the

corrections officers for preshift and postshift work time pursuant to the labor agreements.

2 When the corrections officers filed their original petition in 2012, MOCOA was not a party. It joined as a plaintiff when the corrections officers filed their second amended petition in June 2017. 3 The corrections officers filed an amended petition and a second amended petition, and then amended the second amended petition by interlineation. 4 1 C.S.R. 20-5.010(1)(E) provides:

Employees . . . will be compensated at the regular rate of pay for their positions or, at the discretion of the appointing authority, by allowing an equal amount of compensatory time off for those work assignments which cause the employee to exceed forty (40) hours in pay status during a workweek. An employee shall receive an additional one-half (1/2) time compensation, by pay or compensatory time off, for any hours of work which exceed forty (40) hours actually worked within the workweek. 4 In 2014, MDOC filed a motion for judgment on the pleadings as to Counts I and II,

which the circuit court sustained. MDOC next moved for summary judgment in 2016,

claiming the corrections officers’ breach of contract claims should be treated the same as

freestanding claims for violations of the FLSA and dismissed. The motion was overruled.

In June 2018, the corrections officers filed a motion for partial summary judgment on

their breach of contract claims, Counts III and VI of the petition. Essentially, the corrections

officers sought to have the circuit court determine MDOC was liable on its breach of contract

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