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Sleep More Then 8 Hours? Teams to be compensated.




In their prolonged legal dispute against CRST Expedited and CRST International, a group of truckers led by Juan Carlos Montoya received a favorable ruling from the United States Court of Appeals for the First Circuit on December 12, 2023.


The truckers contended that CRST violated the Fair Labor Standards Act (FLSA) by neglecting to compensate them for time spent in the sleeper berth beyond eight hours within a twenty-four-hour period, with these eight hours designated as a non-compensable sleeping period. The legal case contended that, according to the Fair Labor Standards Act (FLSA), sleeper berth time for team truckers should be regarded as "on-duty" and, consequently, warrant compensation. The truckers asserted that if sleeper berth time were included in the calculation of hours worked, drivers would fall below the stipulated minimum wage standards.


The court determined that CRST's team driving business model gains an advantage from the fact that drivers remain confined within the sleeper berth beyond their eight-hour sleeping period:


"The drivers' usual travel during the time spent in the sleeper berth implies that such time is beneficial to CRST, considering the significance of continuous travel to CRST's operations. CRST's team driving strategy, where drivers alternate between driving and non-driving duties until reaching their destination, enables CRST's trucks to maintain almost continuous motion while adhering to Department of Transportation (DOT) regulations limiting drivers' hours behind the wheel. CRST significantly benefits from the team driving model, completing deliveries in about half the time it would take a solo driver for the same trip."


Indeed, CRST recognizes the importance of drivers' sleeper berth time to the company's financial success, stating that the team driving model allows for 'twice the utilization out of the truck and keeps that cargo moving...twenty hours a day or more. This rapid travel pace is achievable only because the resting driver resets their driving hours in the sleeper berth while their teammate continues to drive.


While the record does not contain examples of drivers’ sleeper berth time being interrupted for work, the nature of the team driving setup means that the driving teammate may call on the resting teammate to provide emergency assistance, even during the mandated ten-hour period defined as “off-duty” by the DOT regulations. See 49 C.F.R. § 395.1(b)(2) (providing that, in “emergency conditions,” a driver may complete the shipment even if the driving time falls outside of the maximum driving time “without being in violation of the provisions of the regulations”).


Admirable outcome for future team drivers and their quality of life.

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