In Sarrazin v. Coastal, Inc., 311 Conn. 581 (2014), the Connecticut Supreme Court analyzed when an employee's travel time between home and work constitutes compensable work time. The Court affirmed the decision of the trial court in holding that a plumber who carried company tools in a company vehicle during his daily commute to his jobsite and home was not entitled to compensation for that travel time. He was, however, entitled to overtime compensation for the after-hours time he spent picking up tools or equipment from the company's warehouse.
Factual Background
The plaintiff was a plumber whose work involved travel from his home to a designated jobsite, which would change occasionally. His daily round-trip travel time was approximately two hours. During his employment, the plaintiff was promoted to foreman and at that point he was provided with a company vehicle for his daily commute to the jobsite.
The plaintiff had to keep some of the employer's tools and equipment in the vehicle to bring back and forth from his home to the jobsite. Occasionally after regular working hours, the plaintiff had to pick up tools and equipment from the company warehouse.
The plaintiff drove the company vehicle until it was totaled in an accident. He then drove his own truck for a period of about eight or nine months until the company provided him with another vehicle. The employer paid him an...
