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Did Employer Provide a Meal Break?

September 17, 2007

A federal district court in San Francisco has ruled in favor of Starbucks on claims that the company failed to provide meal breaks to coffeehouse managers. The case, White v. Starbucks Corp., is one of just a few decisions that offer insight into an employer’s obligations regarding meal periods.

Steve White worked for just 11 days as a Starbucks store manager (nonexempt). He then filed a class action suit, claiming that Starbucks violated California law by failing to provide meal breaks. Starbucks argued that it wasn’t liable because White voluntarily forewent his breaks.

The federal district court has now dismissed the suit, ruling that employers are not required to ensure that employees take meal breaks. The obligation stated in the Labor Code is to "provide" meal periods, meaning only that employers must offer them. Making employers ensurers of meal breaks, said the court, "would be impossible to implement" for employers that have multitudes of employees working different shifts.

Here, there was evidence that it was White’s decision to skip meal breaks, and Starbucks didn’t pressure White or other managers to work through breaks. Also, the court declined to follow a Labor Commissioner opinion letter which took the position that employers must ensure that employees take meal breaks. The court noted that it was bound to decide the case the way it believed the California Supreme Court would rule if presented with the issue. White v. Starbucks Corp., U.S. District Court, Northern District of California, No. C06-3861 VRW (2007)


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