Yes. On March 19, 2026, the Illinois Supreme Court issued a landmark ruling that opens the door to class action lawsuits against employers who require employees to undergo security checkpoints, medical screenings, or other pre-shift activities without paying them for that time. In Johnson v. Amazon.com Services, LLC, the court decided that employees at Amazon distribution centers who spent 10-15 minutes or longer undergoing mandatory COVID-19 temperature checks and symptom screening before clocking in were entitled to be paid for those minutes—and that Illinois law provides no exception for this type of “preliminary” work, unlike federal law. This decision fundamentally changes how employers in Illinois must calculate hours worked and has implications far beyond health screenings.
The ruling potentially opens the door to wage and overtime claims involving security checkpoints, equipment gathering, uniform changes, and any other mandatory pre-shift task that delays an employee from starting their actual job duties. The significance of this decision lies in what it rejects: federal law, under the Portal-to-Portal Act, allows employers to exclude certain preliminary activities from paid time. Illinois law does not have this carve-out. According to the Illinois Supreme Court, the state’s Minimum Wage Law defines “hours worked” broadly to include “all the time an employee is required to be on duty, or on the employer’s premises, or at other prescribed places of work.” Because security screenings happen on the employer’s premises and are mandatory, employees must be paid for them. This article explains what the ruling means, who it affects, what types of work are now at risk under this precedent, and what employees should know if they believe they’ve been shorted on wages.
Table of Contents
- What Did the Illinois Supreme Court Actually Decide About Pre-Shift Security Checkpoints?
- How Does This Differ From Federal Law, and What Are the Limits of This Ruling?
- What Types of Pre-Shift Activities Could Now Trigger Class Action Claims?
- How Can Employees Use This Ruling, and What Are Their Practical Options?
- What Are the Key Distinctions Between Mandatory Activities and Voluntary Conduct That Employers Will Argue?
- What Are the Broader Industry Implications Beyond Amazon?
- What Is the Forward-Looking Impact, and What Should Employers Expect?
What Did the Illinois Supreme Court Actually Decide About Pre-Shift Security Checkpoints?
The court‘s holding was specific but broad in implication. Amazon required its hourly warehouse employees to arrive early and undergo temperature checks and COVID-19 symptom screening questions before they could clock in for their shifts. These screenings took 10-15 minutes or longer. Amazon did not pay employees for this time. Former workers sued, and the case made its way to Illinois’s highest court.
The Illinois Supreme Court ruled that these screenings constitute “hours worked” under the Illinois Minimum Wage Law (IMWL). The court emphasized that Illinois law does not distinguish between “principal activities” and “preliminary or postliminary activities” the way federal law does. Under the Portal-to-Portal Act at the federal level, employers can exclude certain preparatory work. Illinois rejected this framework entirely. If an employee is on the employer’s premises, required to be there, and doing something the employer mandates, the time counts as work and must be compensated. The decision affirmed that the Illinois Department of Labor (IDOL) has authority to determine what qualifies as “hours worked” under state law, reinforcing the agency’s enforcement power.
How Does This Differ From Federal Law, and What Are the Limits of This Ruling?
This decision marks a departure from federal wage law that many employers have relied on for decades. Under the federal Portal-to-Portal Act, employers can exclude certain preliminary activities—such as walking to a workstation, donning safety equipment, or passing through security—from compensable time if a collective bargaining agreement or contract permits it. Illinois has no such exception. The state‘s definition of hours worked is broader and more protective of employees, and the court made clear that state law controls in Illinois. An employer who operates warehouses in multiple states must apply different rules in Illinois than in neighboring states or federal-only operations. However, this ruling does not mean every minute an employee spends on the employer’s property must be paid.
The decision is grounded in mandatory activities—things the employer requires or directs employees to do. If an employee voluntarily arrives early to socialize in a break room, that might not be compensable. The line between mandatory and voluntary is where practical disputes will occur. Additionally, the ruling is specific to Illinois and does not directly change the law in other states. Employers operating nationwide may face a patchwork of different requirements: some states follow the federal model, others may follow Illinois’s approach, and still others have their own rules. The practical limitation is that this ruling applies to work performed in Illinois for employers subject to IMWL.
What Types of Pre-Shift Activities Could Now Trigger Class Action Claims?
The Illinois Supreme Court’s reasoning extends well beyond medical screenings. The decision explicitly noted that employers may now face liability for requiring employees to perform various preliminary tasks without pay: security checkpoint screening, equipment or tool gathering before clocking in, uniform or dress code changes, badge access procedures, training or briefing sessions before the shift officially starts, and metal detector or bag checks. Any mandatory pre-shift activity that takes place on the employer’s premises could be challenged. Consider a retail employee required to clock in only after passing through a security check and bag inspection—that inspection time now looks compensable under the Johnson ruling.
A warehouse worker who must collect required personal protective equipment from a supply area before starting cannot be asked to do that unpaid. A fast-casual restaurant that requires employees to change into uniforms in a break room on-site before their shift begins would owe them for that time. The broader implication is that employers across multiple industries—warehousing, retail, food service, manufacturing, hospitals, and others—who have used unpaid pre-shift procedures are now at legal risk. Employees affected by these practices over months or years could form class actions claiming unpaid wages and overtime. For employees earning overtime rates, the unpaid pre-shift time can be recharacterized as overtime hours, multiplying the damages.
How Can Employees Use This Ruling, and What Are Their Practical Options?
Employees who believe they were not paid for mandatory pre-shift security screenings, health checks, or other required activities have several potential paths forward. First, they can file a wage claim with the Illinois Department of Labor, which can investigate the employer’s wage practices and issue a determination. IDOL can assess back wages owed and penalties. This administrative route is faster and less costly than hiring a private attorney but may result in lower recoveries. Second, employees can file a private lawsuit under the Illinois Minimum Wage Act or pursue class action litigation if multiple workers faced the same unpaid activity. Class actions are particularly powerful because they can recover unpaid wages for everyone affected over a multi-year period, and employees are not individually responsible for legal fees (the prevailing party recovers attorney’s fees in many wage cases).
However, employees face practical hurdles. They need evidence that the pre-shift activity was mandatory, took a documented amount of time, and was not compensated. Good evidence includes emails or policies stating the requirement, witness testimony from coworkers, time tracking records, and pay stubs showing the discrepancy. Statutes of limitations apply: typically three years in Illinois for wage claims, though some claims may be barred by earlier deadlines. The longer an employee waits to file, the fewer years of back wages are recoverable. Employees considering joining or initiating a class action should consult with an employment attorney to understand the timeline and viability of their claim. An attorney can determine whether the class is large enough, whether the damages are significant, and whether the statute of limitations has been met.
What Are the Key Distinctions Between Mandatory Activities and Voluntary Conduct That Employers Will Argue?
Employers will likely argue that some pre-shift activities are not mandatory or that employees voluntarily chose to arrive early. This is where future disputes will turn. An employer might claim that employees did not have to undergo health screening—they could simply not work that day. Courts will scrutinize this argument: if refusing to submit to a screening means losing your job or shift, was it truly voluntary? Practically, employees working paycheck-to-paycheck cannot “volunteer” to skip a required procedure and lose income. Courts tend to disfavor employer arguments that redefine mandatory activities as voluntary. Additionally, an employer that tells employees they must arrive at 7:45 a.m.
To undergo screening before their 8 a.m. shift start has explicitly made the screening mandatory. Implied or written policies that condition continued employment on complying with these procedures will likely be viewed as mandatory rather than voluntary. A limitation to keep in mind: if an employee engages in a purely personal activity that happens to occur on employer premises before their shift, that may not be compensable. For example, an employee who arrives 30 minutes early to use the gym or relax in the break room is not performing a work activity. But the moment the employer directs or requires an activity—even if framed as routine or administrative—the clock should start running. Employers attempting to skirt this ruling by relabeling mandatory activities as “voluntary” or “personal” are likely to face challenges in court, particularly when employees uniformly undergo the same procedure.
What Are the Broader Industry Implications Beyond Amazon?
Amazon was not the first employer to implement these practices, nor will it be the last to be affected by this ruling. The Johnson decision sends a signal across retail, warehousing, manufacturing, healthcare, and other labor-intensive industries that unpaid pre-shift procedures are now legally risky in Illinois. Hospitals that required employees to undergo health screenings at shift change, security checkpoints during the pandemic, or badge access procedures before clocking in may owe back wages to nursing staff, maintenance workers, and other hourly employees. Retail chains with security bag checks or uniform-changing requirements on company premises face similar exposure. Quick-service restaurants with required briefings or uniform changes before clocking in are now potentially liable.
The ruling also affects how multi-state employers must structure their wage practices. A company operating in both Illinois and Indiana cannot apply the same practice uniformly across both states if it violates Illinois law. They must either comply with Illinois’s stricter standard in all states or maintain separate time-tracking systems. Many large employers will likely choose to adopt the more protective standard nationwide to simplify compliance. This could result in better-protected employees everywhere, not just in Illinois, as companies standardize their wage practices upward.
What Is the Forward-Looking Impact, and What Should Employers Expect?
The Johnson ruling is likely to spawn a wave of wage litigation in Illinois, both in class actions and individual claims. Employees who worked at major distribution centers, retail locations, or manufacturing facilities may now realize they were underpaid and pursue claims. Labor attorneys who specialize in wage litigation will likely identify opportunities to represent groups of employees or individual claimants. Employers with warehouses or service facilities in Illinois should conduct a wage audit immediately to identify any unpaid pre-shift activities and calculate the liability. Settling claims quickly and systematically, while implementing compliant wage practices going forward, will likely be less costly than defending multiple lawsuits.
Going forward, Illinois employers must reimagine their pre-shift procedures. If a security checkpoint or health screening is necessary, it must be treated as paid work time. Employers who want to minimize paid time should design workflows to integrate these activities into the paid shift itself—for example, having employees clock in before passing through security rather than after. Some employers may choose to reduce or eliminate non-essential pre-shift requirements. The Johnson decision effectively requires Illinois employers to decide: either pay for these activities or eliminate them. There is no third option of requiring them unpaid.