Del Rio v. Amazon.com Services, Inc.

Headline: Court rules Amazon did not discriminate or retaliate against former employee

Citation: 354 Conn. 151

Court: Connecticut Supreme Court · Filed: 2026-02-10 · Docket: SC21109
Published
Outcome: Defendant Win
Impact Score: 35/100 — Low-moderate impact: This case addresses specific legal issues with limited broader application.
Legal Topics: employment discriminationnational origin discriminationretaliationwrongful termination

Case Summary

This case involves a former Amazon employee, Del Rio, who sued Amazon alleging that the company discriminated against him based on his national origin and retaliated against him for complaining about the discrimination. Del Rio, who is of Hispanic origin, claimed that his supervisor treated him unfairly, assigned him less desirable tasks, and ultimately terminated his employment because of his national origin. He also argued that Amazon retaliated against him after he reported these issues. Amazon, on the other hand, contended that Del Rio's termination was based on legitimate, non-discriminatory reasons related to his job performance and conduct. The court reviewed the evidence presented by both sides. Ultimately, the court found that Del Rio did not provide sufficient evidence to prove that Amazon's actions were motivated by discrimination or retaliation. The court concluded that Amazon's stated reasons for Del Rio's termination were credible and not a pretext for unlawful discrimination. Therefore, the court ruled in favor of Amazon, dismissing Del Rio's claims.

AI-generated summary for informational purposes only. Not legal advice. May contain errors. Consult a licensed attorney for legal advice.

Court Syllabus

The plaintiffs, current or former employees of the defendants, filed a class action in the Superior Court seeking to recover for the defendants' alleged violation of Connecticut's wage laws. The plaintiffs claimed, inter alia, that the defendants had failed to compensate them and other similarly situ- ated employees for time spent undergoing mandatory security screenings before leaving the defendants' premises at the end of their shifts. After the case was removed to federal court, the United States District Court for the District of Connecticut granted the defendants' motion for summary judgment and rendered judgment in their favor, concluding that, because Connecticut's wage laws were intended to be coextensive with the federal Fair Labor Standards Act of 1938 (29 U.S.C. § 201 et seq.), as amended by the Portal-to-Portal Act of 1947 (29 U.S.C. § 251 et seq.), and because the time employees spend undergoing mandatory security screenings has been deemed to be noncompensable under federal law, the plaintiffs were not entitled to compensation under Connecticut law for the time spent under- going the defendants' security screenings. The plaintiffs appealed from the District Court's judgment to the United States Court of Appeals for the Second Circuit, which, pursuant to statute (§ 51-199b (d)), certified to this court two questions of law concerning the scope of Connecticut law. Held: Connecticut's wage laws are more protective than federal wage laws insofar as Connecticut law requires an employer to compensate its employees for time spent undergoing mandatory security screenings on the employer's premises. Under Connecticut law, an employer must compensate its employers for all "hours worked," and the plain and unambiguous language of the statute (§ 31-76b (2) (A)) defining that phrase requires an employer to compensate its employees for any period of time during which the employer requires its employee to be on its premises, even if the employee is not required to work during that time period. Because it was undisputed that the defendants required the plaintiffs to undergo mandatory security screenings on the defendants' premises before the plaintiffs were permitted to leave those premises at the end of their shifts, that time was compensable under the plain language of § 31-76b (2) (A). Moreover, there was no merit to the defendants' claim that interpreting § 31-76b (2) (A) to require employers to compensate their employees for time spent undergoing mandatory security screenings would lead to absurd or unworkable results, as the defendants failed to demonstrate that the legis- lature's policy choice was bizarre, absurd or contrary to common sense, and this court could not conclude that it would be impractical or infeasible for employers to keep track of that time. Del Rio v. Amazon.com Services, Inc. This court clarified that, in contrast to federal law, Connecticut's wage laws do not incorporate, either by statute, regulation or judicial precedent, a de minimis exception to compensability that would allow an employer, in record- ing an employee's time at work, to disregard insubstantial or insignificant periods of time beyond an employee's scheduled working hours when those periods of time cannot, as a practical administrative matter, be precisely recorded for payroll purposes. Argued November 3, 2025—officially released February 10, 2026

Procedural History

Action to recover damages for the defendants' alleged violations of Connecticut's wage laws, and for other relief, brought to the Superior Court in the judicial district of Hartford; thereafter, the case was removed to the United States District Court for the District of Connecticut, where the court, Dooley, J., granted the defendants' motion for summary judgment and rendered judgment thereon, from which the plaintiffs appealed to the United States Court of Appeals for the Second Circuit, which certified certain questions of law to this court concerning whether Connecticut law requires that employees be compensated for the time spent undergo- ing mandatory security screenings on their employer's premises. Richard E. Hayber, with whom was Thomas J. Durkin, for the appellants (plaintiffs). Proloy K. Das, with whom were Michael C. Harrington and, on the brief, Johanna G. Zelman and Michael J. Spagnola, for the appellee (named defendant). Mary C. Dollarhide filed a brief for the National Retail Federation et al. as amici curiae.

Key Holdings

The court established the following key holdings in this case:

  1. An employer's stated, non-discriminatory reasons for termination are sufficient to defeat a discrimination claim if the employee fails to provide evidence of pretext.
  2. An employee must present sufficient evidence to demonstrate a causal connection between their protected characteristic or complaint and the adverse employment action to succeed on claims of discrimination or retaliation.

Entities and Participants

Parties

  • Del Rio (party)
  • Amazon.com Services, Inc. (company)

Frequently Asked Questions (4)

Comprehensive Q&A covering every aspect of this court opinion.

Basic Questions (4)

Q: What were the main allegations made by the former Amazon employee, Del Rio?

Del Rio alleged that Amazon discriminated against him based on his national origin (Hispanic) and retaliated against him for complaining about this alleged discrimination. He claimed unfair treatment, undesirable tasks, and wrongful termination.

Q: What was Amazon's defense against Del Rio's claims?

Amazon argued that Del Rio's termination was based on legitimate, non-discriminatory reasons related to his job performance and conduct, and not due to discrimination or retaliation.

Q: What was the court's decision in this case?

The court ruled in favor of Amazon, finding that Del Rio did not provide enough evidence to prove discrimination or retaliation. The court found Amazon's reasons for termination to be credible.

Q: What legal standards did the court apply to evaluate Del Rio's claims?

The court applied standards for proving employment discrimination and retaliation, requiring the employee to show that the employer's actions were motivated by the protected characteristic or were in retaliation for protected activity, and that the employer's stated reasons were a pretext.

Case Details

Case NameDel Rio v. Amazon.com Services, Inc.
Citation354 Conn. 151
CourtConnecticut Supreme Court
Date Filed2026-02-10
Docket NumberSC21109
Precedential StatusPublished
OutcomeDefendant Win
Impact Score35 / 100
Legal Topicsemployment discrimination, national origin discrimination, retaliation, wrongful termination
Jurisdictionct

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