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Meyer v. United States

2026-08-26

Summary

Holding. The Court denies the United States' motion to partially dismiss the complaint. The correctional officers have alleged sufficient facts to plausibly claim that pre-shift security screening and sally port passage time may be compensable under the Fair Labor Standards Act because such activities could be integral and indispensable to their principal duty of maintaining prison safety and security, a matter requiring factual development beyond the motion to dismiss stage.

Correctional officers at a federal prison facility sued the United States for unpaid overtime compensation under the Fair Labor Standards Act, claiming they performed work during time periods before and after their scheduled shifts. Specifically, they alleged that time spent passing through security screening in the prison lobby and walking through a secure passageway called a sally port should be compensable because these activities were either part of their principal job duties of maintaining prison safety and security, or were integral and indispensable to performing those duties. The United States moved to dismiss these claims, arguing that security screenings and the sally port passage were merely preliminary activities and not compensable work.

The court concluded that the officers had alleged sufficient facts to state a plausible claim for compensation. The court found that under the Fair Labor Standards Act and Supreme Court precedent, an activity can be compensable when it is an intrinsic element of a worker's principal duties and cannot be eliminated without impairing the worker's ability to perform those duties. Applying this standard, the court determined that factual disputes existed regarding whether the security screening and sally port activities were necessary to the officers' duty to maintain prison safety and security, and whether the officers were required to remain vigilant and respond to emergencies during these time periods. Because these questions of fact could not be resolved at the motion to dismiss stage, the court denied the government's motion.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether security screening activities performed before scheduled shifts are compensable as integral and indispensable to correctional officers' principal duties
  • Whether passage through a sally port is compensable work or non-compensable ingress
  • Whether correctional officers must remain vigilant and respond to emergencies during pre-shift and post-shift activities within prison facilities

Procedural posture

The Court of Federal Claims considered a motion to partially dismiss filed by the United States under Federal Rule of Civil Procedure 12(b)(6) following the filing of an amended complaint by current and former correctional officers employed by the Bureau of Prisons.

Authorities cited

Opinion

majority opinion

In the United States Court of Federal Claims

ERIC MEYER, et al.,

Plaintiffs,

No. 25-cv-1535

v.

Filed: August 26, 2026

THE UNITED STATES,

Defendant.

John W. Stewart of McGillivary Steele Elkin LLP, Washington, D.C., argued for Plaintiff. With him on the briefs was Rachel Lerner of McGillivary Steele Elkin LLP, Washington, D.C.

Brendan D. Jordan of the United States Department of Justice, Civil Division, Washington, D.C., argued for Defendant. With him on the briefs were Patricia M. McCarthy, Brett A. Shumate, and Reginald T. Blades, Jr. of the United States Department of Justice, Civil Division, Washington, D.C.

MEMORANDUM AND ORDER

Federal Correctional Institution Mendota (FCI Mendota or prison), in Mendota, California

is a medium security correctional facility housing male inmates who have been convicted of federal

crimes, including narcotics distribution, rape, murder, and other violent offenses. ECF No. 10

(Amended Complaint or Am. Compl.) ¶ 9. Inmates serve sentences of varying lengths, up to life

sentences. Id. Plaintiffs are current and former employees of the U.S. Department of Justice,

Bureau of Prisons and work as correctional officers at FCI Mendota. Id. ¶ 5. Plaintiffs allege that

their “principal activity is maintaining the safety and security of the Institution,” a task that they

allege they must perform “every moment that they are within the Institution from the moment they

begin clearing the mandatory screening prior to their scheduled shifts until they exit the secure

confines of the Institution after their scheduled shifts.” Id. ¶ 10. Plaintiffs allege that they have worked in excess of the hours permitted by the Fair Labor Standards Act (FLSA), 29 U.S.C. § 207,

and are therefore entitled to overtime compensation for all hours worked in excess of eight hours

in a workday or 40 hours in a workweek. Am. Compl. ¶¶ 1, 8.

Plaintiffs allege that they perform uncompensated work for at least 15-30 minutes each

shift, and sometimes more after the end of their scheduled shifts. Id. ¶ 15. According to Plaintiffs,

this uncompensated time begins when Plaintiffs “start the process of clearing the staff screening

site” in the lobby of the prison. Id. ¶ 18. After clearing the screening, Plaintiffs don their duty

belts and other equipment and then proceed to the “Control Center sally port” where they flip their

accountability chit, proceed through the sally port, “walk down an outdoor walkway and clear a

locked slider gate” and then are locked inside the prison compound and proceed to their posts. 1

Id. ¶ 21.

On January 16, 2026, Defendant filed a Motion to Partially Dismiss the Complaint pursuant

to Rule 12(b)(6). ECF No. 11 (Motion). Defendant seeks to dismiss only Plaintiffs’ claims for

overtime compensation for time spent clearing the security screening in the lobby of the prison,

and the time spent passing through the sally port prior to the start of their paid shifts. Id. at 6. For

the reasons explained below, the Court DENIES Defendant’s Motion to Partially Dismiss the

Complaint (ECF No. 11).

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A sally port is “a secure entryway . . . that consists of a series of doors or gates,’ that [P]laintiffs pass through on the way to their duty station.” ECF No. 11 (Motion or Motion to Dismiss) at 15 (quoting “Sally port,” Merriam Webster, https://www.merriamwebster.com/dictionary/sally%20port).

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FACTUAL BACKGROUND

Plaintiffs are current and former correctional workers “employed by the United States

Department of Justice, Bureau of Prisons, at FCI Mendota in Mendota, California.” Am. Compl.

¶ 5. They allege that “FCI Mendota is a medium security correctional facility that houses hundreds

of male inmates who have been convicted of federal crimes, including violent offenders.” Id. ¶ 9.

The facility “is staffed 24 hours per day, 365 days a year by correctional officers, including

Plaintiffs,” who are assigned to 8-hour shifts at posts requiring surveillance coverage for 8, 16, or

24 hours per day. Id. ¶¶ 10–12. Plaintiffs allege that there is no paid overlap between officers as

they transition between shifts, so that Plaintiffs are required to “be on their assigned posts, in

uniform and with all assigned equipment and pertinent post information, by the scheduled start of

their paid shift.” Id. ¶ 13. As a result, when assigned to a 24-hour post, plaintiffs perform “at

least 15–30 minutes” of overtime work before and after their shifts without compensation. Id. ¶¶

14–15.

Plaintiffs allege that their unpaid pre-shift work begins “when they start the process of

clearing the staff screening site in the front lobby,” where they “work [] to ensure no contraband

enters the Institution” as required by Defendant. Id. ¶ 18. According to Plaintiffs, this screening

is required by Defendant to ensure that “weapons and other contraband” are kept out of the

Institution, and the screenings cannot be eliminated without “impairing the Plaintiffs’ ability to

complete their work because they could not guarantee a contraband-free environment.” Id. They

then “collect and don their duty belts . . . which are essential and required to securely hold keys

and access mandatory equipment.” Id. ¶ 19. Plaintiffs cannot don their duty belts earlier because

the belts, “with metal chains and chits,” would set off the metal detector at the staff screening site.

Id. Afterward, Plaintiffs proceed to the Control Center Sally Port, where they are visually

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identified by a Control Center officer who then allows them into the sally port where they “flip

their accountability chit signifying that they are on duty.” Id. ¶ 21. Plaintiffs allege they then

continue actively “maintaining safety and security” as they walk to their assigned posts because

they are “in uniform and identifiable to the inmates and staff as correctional officers, and remain

vigilant, alert, and ready to (and do) respond to emergencies.” Id. ¶ 20.

Plaintiffs allege that they perform additional post-shift activities without compensation,

including “exchanging information and equipment on the assigned post with oncoming staff,

remaining vigilant, alert, and ready to respond to emergencies while within the secured confines

of the Institution, supervising and monitoring inmates, observing and correcting inmate behavior,

looking for contraband,” and responding to alarms. Id. ¶ 30. Plaintiffs state they are required to

respond to emergencies in their unpaid time when walking to and from their posts, and failure to

do so would result in disciplinary action. Id. ¶ 31.

Plaintiffs allege that they spend at least 15-30 minutes per shift performing “compensable”

but unpaid work: clearing the security screening, walking to their posts, exchanging information

and equipment, and walking from their posts. Id. ¶ 33. Throughout these activities, Plaintiffs

allege they are “maintaining safety and security” in the prison by “maintaining constant vigilance

to monitor for contraband and ensure that nothing out of the ordinary is occurring, and immediately

addressing any issues including, correcting inmate behavior and interacting with inmates, no

matter the location and time of day that it occurs” and “running to locations where body alarms

sound, and responding to other emergencies as they arise.” Id. ¶¶ 10, 22–23. Plaintiffs seek

“backpay and liquidated damages in an amount equal to their backpay” due to defendant’s failure

to pay overtime in compliance with the FLSA. Id. ¶ 45. Plaintiffs also seek attorneys’ fees and

costs. Id. ¶ 47.

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PROCEDURAL HISTORY

Plaintiffs filed their Complaint on September 16, 2025. ECF No. 1 (Complaint). On

December 19, 2025, Plaintiffs filed a Motion for Leave to Amend Complaint to update the caption

“to include the names of 137 party-plaintiffs who opted into this litigation on September 25, 2025.”

ECF No. 9 at 1 (Motion for Leave to File). The Court granted the Motion for Leave to File on

December 22, 2025, and Plaintiffs filed their Amended Complaint on the same day. Minute Order

dated Dec. 22, 2025; Am. Compl.

On January 16, 2026, Defendant filed its Motion to Partially Dismiss the Complaint.

Motion. On February 13, 2026, Plaintiffs filed their Opposition to Defendant’s Motion to Partially

Dismiss the Complaint. ECF No. 12 (Response). On March 6, 2026, Defendant filed its Reply in

Support of Defendant’s Motion to Dismiss Part of the Complaint. ECF No. 14 (Reply). On March

11, 2026, Plaintiffs filed a Notice of Supplemental Authority regarding Hodge v. North Carolina

Dept. of Adult Correction, No. 5:19-cv-478-BO, 2026 WL 579933 (E.D.N.C. Mar. 2, 2026). ECF

No. 16 (Notice I). On March 30, 2026, Plaintiffs filed a Notice of Supplemental Authority

regarding Stroup v. United States, 180 Fed. Cl. 346 (2026). ECF No. 19 (Notice II). On April 14,

2026, Defendant filed a Response to Notice II. ECF No. 20 (Response to Notice II). The Court

held oral argument on this Motion on May 12, 2026. Minute Order dated May 12, 2026.

LEGAL STANDARD

I. Rule 12(b)(6)

To withstand a motion to dismiss pursuant to Rule 12(b)(6), “a complaint must contain

sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544,

570 (2007)). A plaintiff also must establish “more than a sheer possibility that a defendant has

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acted unlawfully.” Id. (citing Twombly, 550 U.S. at 556). “The Court of Federal Claims may

properly grant a motion to dismiss under [Rule] 12(b)(6) when a complaint does not allege facts

that show the plaintiff is entitled to the legal remedy sought.” Steffen v. United States, 995 F.3d

1377, 1379 (Fed. Cir. 2021) (citing Lindsay v. United States, 295 F.3d 1252, 1257 (Fed. Cir.

2002)).

“Conclusory allegations of law and unwarranted inferences of fact do not suffice to support

a claim.” Bradley v. Chiron Corp., 136 F.3d 1317, 1322 (Fed. Cir. 1998). However, at the motion

to dismiss stage, this Court must “take all factual allegations in the complaint as true and construe

the facts in the light most favorable to the non-moving party.” Boyd v. United States, 134 F.4th

1348, 1352 (Fed. Cir. 2025) (quoting Jones v. United States, 846 F.3d 1343, 1351 (Fed. Cir. 2017)).

At the motion to dismiss stage, “detailed factual allegations” are not necessary. Twombly, 550

U.S. at 555.

STATUTORY FRAMEWORK

I. The Fair Labor Standards Act

In 1938, Congress enacted the Fair Labor Standards Act (FLSA) to require overtime

compensation at a rate of one and one-half an employee’s regular rate for employees who work

more than 8 hours a day or 40 hours in a work week. 29 U.S.C. § 207(a)(1); see also 5 C.F.R.

§ 551.501(a). The Department of Labor (DOL) is responsible for implementing the FLSA for nonfederal workers, and the Office of Personnel Management (OPM) for federal workers. 29 U.S.C.

§§ 204(a), (f). Congress subsequently passed the Portal–to–Portal Act which amended the FLSA

and clarified that the following activities are exempt from coverage under the FLSA:

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(1) walking, riding, or traveling to and from the actual place of performance of the

principal activity or activities which such employee is employed to perform,

and

(2) activities which are preliminary to or postliminary to said principal activity or

activities,

which occur either prior to the time on any particular workday at which such

employee commences, or subsequent to the time on any particular workday at

which he ceases, such principal activity or activities.

29 U.S.C. § 254(a).

However, the Supreme Court has held that “activities performed either before or after the

regular work shift . . . are compensable under the portal-to-portal provisions of the [FLSA] if those

activities are an integral and indispensable part of the principal activities for which covered

workmen are employed.” Steiner v. Mitchell, 350 U.S. 247, 256 (1956). “An activity is . . .

integral and indispensable to the principal activities that an employee is employed to perform if it

is an intrinsic element of those activities and one with which the employee cannot dispense if he

is to perform his principal activities.” Integrity Staffing Sols., Inc. v. Busk, 574 U.S. 27, 33 (2014).

In Integrity Staffing, the Supreme Court held that time spent by warehouse employees

going through an anti-theft security screening at the end of the workday was not compensable,

because undergoing these screenings was not an “intrinsic element of retrieving products from

warehouse shelves or packaging them for shipment” and because the employer could have

“eliminated the screenings altogether without impairing the employees’ ability to complete their

work.” Id. at 35.

II. The Continuous Workday Doctrine

The Portal-to-Portal Act contains a provision that defines certain activities, like walking,

as non-compensable when they “occur either prior to the time on any particular workday at which

[an] employee commences, or subsequent to the time on any particular workday at which he

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ceases, such principal activity or activities.” 29 U.S.C. § 254(a). However, “[c]ourts have

interpreted this portion of the statute to mean that activities which would otherwise be excluded

from the FLSA by the Portal-to-Portal Act could be compensable if they occur during the

employees’ ‘workday.’” Stroup, 180 Fed. Cl. at 355 (citing IBP, Inc. v. Alvarez, 546 U.S. 21, 28–

29 (2005)). This is the “continuous workday rule.” Alvarez, 546 U.S. at 29–30.

DISCUSSION

Defendant seeks to dismiss Plaintiffs’ claims for (i) time spent passing through the preshift security screening, and (ii) time spent in the sally port. Construing all facts in the light most

favorable to Plaintiffs, Plaintiffs have alleged sufficient facts in their Amended Complaint to

plausibly claim that the time they spent undergoing the prison’s security screening and passing

through the sally port is either part of their principal activity or is integral and indispensable to

their principal activity of employment.

I. The Security Screening Claim

Defendant asserts that Plaintiffs have failed to state an FLSA claim for time spent passing

through the security screening prior to their shifts because (1) passing through a security screening

is not a principal activity that the plaintiffs are employed to perform and (2) it is also not integral

or indispensable to a principal activity. Mot. at 13. Defendant argues that, as a matter of law,

“security screenings are neither principal activities nor integral or indispensable to principal

activities.” Mot. at 14 (quoting Baytos v. United States, 175 Fed. Cl. 360, 371 (2025) (Baytos II)

and citing Medrano v. United States, 159 Fed. Cl. 537, 545 (2022), Alkire v. United States, 158

Fed. Cl. 380, 391–93 (2022), and Aitken v. United States, 162 Fed. Cl. 356, 365 (2022)). Defendant

argues that this case is analogous to Integrity Staffing, where the Supreme Court concluded that

post-shift anti-theft security screenings for warehouse workers were not integral and indispensable

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to their duties, but instead that the security screening is “essentially part of the ingress . . . process”

of arriving at Plaintiffs’ duty post. Mot. at 14 (quoting Integrity Staffing, 574 U.S. at 38

(Sotomayor, J., concurring)).

In response, Plaintiffs argue that the correctional officers undergoing security screening in

this case are distinct from the warehouse workers undergoing security screening in Integrity

Staffing, since there, the security screening of the warehouse workers was not “tied to” their

principal activities, whereas here the screening is “tied to” Plaintiffs’ principal activity of

maintaining the safety and security of the prison. Resp. at 19–20; see Integrity Staffing, 574 U.S.

at 36 (“The integral and indispensable test is tied to the productive work that the employee is

employed to perform.” (emphasis in original)). In Integrity Staffing, the Supreme Court held that

an activity is integral and indispensable to the principal activities an employee is employed to

perform when “it is an intrinsic element of those activities and one with which the employee cannot

dispense if he is to perform his principal activities.” Id. Plaintiffs argue that here, searching for

contraband is an intrinsic element of their principal activity, and they could not dispense with

undergoing the security screening without “impairing the officers’ ability to provide security and

search for contraband” since there would be no way to guarantee that Plaintiffs themselves are not

invertedly introducing contraband into the prison environment. Resp. at 17, 19 (citing Aguilar v.

Mgmt. & Training Corp., 948 F.3d 1270, 1279 (10th Cir. 2020)); Am. Compl. ¶ 18. Defendant

contends that on the contrary, even if the prison had no security screening process for Plaintiffs

and instead Plaintiffs were trusted to “police themselves to not bring any contraband into the

prison” that they could still perform their principal activity. Mot. at 16 (citing Integrity Staffing,

574 U.S. at 33 and Medrano, 159 Fed. Cl. at 545).

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Whether the security screening could be dispensed with without impairing the Plaintiffs’

ability to perform their principal activity, as Plaintiffs have plausibly alleged in their complaint, is

a question of fact that cannot be resolved at the motion to dismiss stage. See, e.g., Stroup, 180

Fed. Cl. at 353 (rejecting Defendant’s argument that if the prison “did not conduct security

screening[s] and trusted the [P]laintiffs to police themselves to not bring any contraband into the

prison, [P]laintiffs could still perform the principal activities they are employed to perform” as

“rely[ing] on fact-finding” that could not be resolved on a motion to dismiss (alterations in

original)). Plaintiffs have plausibly claimed that eliminating the screening would interfere with

their principal activity of maintaining safety and security in the prison since eliminating the

screenings would “impair[] the Plaintiffs’ ability to complete their work because they could not

guarantee a contraband-free environment.” Am. Compl. ¶ 18; Integrity Staffing, 574 U.S. at 35

(“[A]n activity is not integral and indispensable to an employee’s principal activities unless it is

an intrinsic element of those activities and one with which the employee cannot dispense if he is

to perform those activities.”). Accordingly, Plaintiffs have alleged facts sufficient to withstand a

motion to dismiss. See Rule 12(b)(6).

Moreover, even if this was not the case, Plaintiffs and Defendant also agree that there is a

factual dispute as to whether Plaintiffs perform additional duties tied to their principal activity

while they undergo the security screening, in addition to preventing contraband from entering the

facility. Am. Compl. ¶ 10 (Plaintiffs’ principal activity is “maintaining the safety and security” of

the prison, an activity they perform “from the moment they begin clearing the mandatory security

screening prior to their scheduled shift” and which they perform by “maintaining constant

vigilance to monitor for contraband and to ensure that nothing out of the ordinary is occurring,

[and] correcting inmate behavior and interacting with inmates.”); ECF No. 22 (Oral Argument

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Transcript or OA Tr.) at 58:6–15 (Plaintiffs’ counsel: “One other way in which they’re performing

their principal activity in the lobby itself is by . . . correct[ing] any problems they see with those

inmates. That is them performing their duty to be ready to do that in the presence of inmates as

they proceed into the institution.”); OA Tr. at 85:3–4 (The Court: “So you’re saying they’re on

duty as soon as they sort of get to that front lobby?”); id. at 85:8–15 (Defendant’s counsel: “I think

there’s a question of . . . well, if they’re on their way to their post and a fight breaks out or an

inmate does something, can the correction officer say, ‘I don’t care,’ . . . I’ve heard different things

from different managers of prison.”). As Plaintiffs have alleged that they perform other duties

while in the lobby undergoing the security screening, specifically remaining vigilant to anything

out of the ordinary and interacting with inmates who may be present, and as Defendant concedes

that this factual claim is an open question that cannot be resolved at this stage, the Court cannot

characterize the time Plaintiffs spend passing through the screening as mere non-compensable

“ingress” as a matter of law. Am. Compl. ¶ 10; Mot. at 13; OA Tr. 80:2–4 (Defendant’s counsel:

“I think if we go to discovery, it will show that . . . inmates are not present in the front lobby.”);

Medrano, 159 Fed. Cl. at 550 (denying a motion to dismiss for time correctional officer plaintiffs

spent walking to their posts because plaintiffs had alleged that they were “‘correct[ing] inmate

behavior, ‘respond[ing] to any security breaches,’ ‘identify[ing] safety issues,’ [and] handling

emergencies” while walking); Baytos II, 175 Fed Cl. at 372 (declining to decide as a matter of law

that work was not compensable when disputed issues of fact remained concerning “how often

[correctional officers] encounter prisoners in this area and what the [correctional officers] are

required to do”). Accordingly, for this reason and based upon the allegations in Plaintiffs’

Amended Complaint, at this stage the Court must deny the Motion as to the time Plaintiffs spend

passing through the security screening. See Rule 12(b)(6).

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II. The Sally Port Claim

Defendant also moves to dismiss any claims related to the time that Plaintiffs spend passing

through the sally port on the way to their assigned shifts. Mot. at 20. Defendant argues that passing

through a sally port is not a principal activity, nor is it integral or indispensable to a principal

activity, but instead that it is merely ingress into the prison facility. Id. at 21.

Plaintiffs argue that they are performing their principal activities of maintaining the safety

and security of the prison while passing through the sally port. Resp. at 30. Plaintiffs also assert

that this time is compensable under the continuous workday doctrine, since they pass through the

sally port immediately after donning their work equipment and since many courts and other

arbitrators, including the Court of Federal Claims, have recognized donning work equipment as

“integral and indispensable” to the work of correctional officers in other prisons. Id. at 23–24

(citing Adegbite v. United States, 156 Fed. Cl. 495, 507–08 (2021); Maciel v. City of Los Angeles,

569 F. Supp. 2d 1038, 1049 (C.D. Cal. 2008); Echeverria v. Nevada, No. 3:14-cv-320, 2022 WL

1652450, *12 (D. Nev. May 23, 2022); AFGE Local 525 v. FCI Williamsburg, FMCS No. 08-56529 (May 22, 2012) (Harris, Arb.) at 68-72). Plaintiffs contend that therefore, under the

continuous workday doctrine, all time spent after the “first principal activity of the day [until] the

conclusion of the last principal activity of the day,” including time spent in the sally port, is

compensable work. Id. at 24–25.

A. Plaintiffs sufficiently allege that the time in the sally port is compensable work.

As noted, Plaintiffs contend they have sufficiently alleged that the time they spend in the

sally port is compensable work, since from the “moment correctional officers pass through the

sally port, they are locked inside the Institution, with all the dangers, responsibilities, and job duties

that entails.” Resp. at 29–30. As asserted in their Amended Complaint, Plaintiffs claim that at all

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times after they “clear the staff screening site,” they are performing their principal activity of

“maintaining the safety and security of the Institution” because they “at all times, are in uniform

and identifiable to the inmates and staff as correctional officers, and remain vigilant, alert, and

ready to (and do) respond to emergencies.” Am. Compl. at ¶¶ 10, 20. Defendant counters that the

time plaintiffs spend in the sally port is nothing more than part of a “non-compensable ingress

process” to reach their assigned posts and is therefore not “integral or indispensable to [P]laintiffs’

work.” Mot. at 21. At the current motion to dismiss stage, Plaintiffs have alleged sufficient facts

in their Amended Complaint to make a plausible claim that they are either performing their

principal activity of maintaining the safety and security of the institution while in the sally port or

performing activities that are integral and indispensable to their principal activity.

Principal activities are those activities which employees are “employed to perform” and an

activity is “‘integral and indispensable’ if it is an intrinsic element of the employee’s principal

activities and one with which the employee cannot dispense if he is to perform his principal

activities.” Integrity Staffing, 574 U.S. at 28. Here, Plaintiffs allege that their principal activity is

maintaining the safety and security of the prison, and that for all times after they clear the staff

security screening site, that they perform this principal activity “on the way to their assigned posts

inside the secure confines of the Institution because they, at all times, are in uniform and

identifiable to the inmates and staff as correctional officers, and remain vigilant, alert, and ready

to (and do) respond to emergencies.” Am. Compl. ¶¶ 10, 20 (emphasis added). Plaintiffs pass

through the sally port after passing through the staff security screening and therefore allege that

they are performing these duties while in the sally port. Id. ¶¶ 19, 20. The Court finds it to be at

least plausible that correctional officer Plaintiffs are required to remain vigilant, alert, and ready

to respond to emergencies even while in a sally port as part of their commute to their posts. See

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e.g., Stroup, 180 Fed. Cl. at 354 (“The officers’ description of the activities they perform while in

the sally port sufficiently support[s] the allegation that passing through the sally port is, at least,

integral and indispensable to their principal activity of ‘maintaining security’ . . . includ[ing] being

in uniform and available to respond to emergencies as they arise, which reflect the principal duties

of a correctional officer.”); Baytos I, 2022 WL 598742 at *8 (finding that plaintiffs’ claim that

“clearing the sally port . . . [is] integral and indispensable to their principal activity of maintaining

the safety and security of the Institution” to be plausible “because, among other things, they, at all

times, are in uniform, [and] identifiable to the inmates and staff as correctional officers”).

Moreover, at oral argument Defendant acknowledged that the extent to which Plaintiffs

may be required to respond to emergencies while passing through the sally port is in dispute. OA

Tr. at 82:15–83:2 (“[I]f there’s an emergency, . . . the facts of whether they can, whether they do,

that’s all to be decided later.”). Accordingly, at this initial stage, Plaintiffs have alleged sufficient

facts to withstand the motion to dismiss for time spent passing through the sally port. See Am.

Compl. ¶ 20. 2

2

Plaintiffs also assert that they are entitled to compensation for time spent passing through the sally port under the continuous workday doctrine. Am. Compl. ¶ 20; Resp. at 23. Defendant argues that the continuous workday doctrine does not apply to federal employees. Mot. at 22 (citing Baytos II, 175 Fed. Cl. at 369). As the Court has already denied the Motion as to the sally port claim on a different theory, the Court “declines to issue an advisory opinion” addressing the applicability of the continuous workday doctrine at this stage since it is not necessary to rule on the Motion. See Bieganowski v. United States, No. 26-165, 2026 WL 2225221, at *8 n.5 (Fed. Cl. July 14, 2026) (declining to address additional jurisdictional arguments after the Court had already found that it lacked jurisdiction).

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CONCLUSION

For the reasons stated above, the Court DENIES Defendant’s Motion to Partially Dismiss

the Complaint (ECF No. 11).

IT IS SO ORDERED.

Eleni M. Roumel

ELENI M. ROUMEL

Judge

August 26, 2026

Washington, D.C.

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