BOSTON, MA — A recent decision from the First Circuit Court of Appeals has established that team drivers are entitled to compensation for time spent in the sleeper berth beyond the initial eight-hour period. This ruling stems from a long-standing legal battle involving CRST Expedited and CRST International, centered on whether extended downtime in a moving truck constitutes compensable hours under the Fair Labor Standards Act (FLSA).

The dispute originated in January 2016 when Juan Carlos Montoya and a group of former CRST trainees challenged the carrier's compensation structure. CRST utilizes a unique team-driving model designed to keep equipment in near-continuous motion across the country. While Department of Transportation rules dictate hours of service, the Department of Labor manages how those hours are paid. The court found that when sleeper time exceeding eight hours is factored into total hours worked, the resulting hourly pay for some drivers dropped below the federal minimum wage.

CRST’s fleet operations rely on keeping trucks moving for days at a time to maximize efficiency. The court noted that while drivers have the freedom to read, browse the internet, or sleep while their partner is behind the wheel, that time must be accounted for if it exceeds the eight-hour daily exclusion permitted by labor regulations. The initial district court ruling in Massachusetts sided with the drivers, and CRST has since pushed the issue through the appeals process to contest the liability.

What This Means for Drivers

This ruling is a significant development for any CDL-A driver working in team operations or considering OTR truck driver positions with large fleets. If your current pay model relies on a per-mile rate that ignores extended sleeper time, you may be seeing your effective hourly wage dip below legal standards. Drivers should review their pay stubs and settlement sheets to determine if the time they spend in the berth is being accurately logged and compensated according to federal standards. This decision provides a legal basis for challenging pay practices that treat mandatory downtime as unpaid, even when a driver is not truly free to leave the vehicle.

Industry Reaction

The carrier industry remains divided on how to reconcile FMCSA regulations with the Fair Labor Standards Act. For years, major trucking companies hiring team drivers have operated under the assumption that the sleeper berth was strictly off-duty time. This court intervention forces a re-evaluation of how carriers calculate miles and pay periods. As legal precedents continue to evolve, fleets may be forced to shift away from pure mileage-based pay to hourly models to ensure compliance and avoid massive back-pay liabilities.

Key Points

• The First Circuit Court of Appeals ruled that sleeper berth time exceeding eight hours must be counted toward FLSA minimum wage calculations.
• The case began in 2016 with a lawsuit filed by former CRST trainee drivers.
• CRST’s team-driving model allows for near-continuous vehicle movement, which the court analyzed to determine if time spent in the berth was truly off-duty.
• The ruling clarifies that Department of Labor pay regulations are distinct from DOT hours-of-service rules regarding what constitutes compensable work.

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