Washington State Court Enforces Remedies for Employee Meal Break Violations

Automatic Meal Break Deductions and Unpaid Work Time

Many employers automatically deduct meal breaks from employees’ paychecks, regardless of whether the employee actually takes the break. While this practice may seem routine, it raises serious legal concerns—especially when employees are routinely required to work through those unpaid breaks. In some states, this conduct is not just unlawful but may even carry criminal consequences for employers.

In Massachusetts, for example, failing to provide legally required meal breaks can result in criminal liability for the employer. However, beyond the question of penalties for employers, employees often ask a critical follow-up question: How much compensation are they entitled to receive for the time they worked but were never paid?

Courts across the country have approached this issue differently, with some rulings offering stronger protections for workers than others.

How Courts View Unpaid Meal Break Work

At its core, the issue is simple: when an employee works during a meal break that is automatically deducted from their wages, that time is compensable work time. The complexity arises when determining how that time should be paid—at the employee’s regular rate or at an overtime premium rate.

Courts have increasingly recognized that automatic deductions, without safeguards to ensure employees actually receive uninterrupted breaks, create a risk of systemic wage theft. Employers may benefit financially while employees lose compensation for time spent working.

Massachusetts Federal Court Guidance on Unpaid Time

A key ruling on this issue came from the United States District Court for the District of Massachusetts, where Judge Nancy Gertner addressed the legality of unpaid meal break work.

In that decision, the court made a clear and straightforward finding: an hour worked is an hour that must be paid. If an employee works through a meal break, the employer cannot lawfully deduct that time from wages. While this ruling clarified that unpaid meal break work must be compensated, it left open an important question—whether that compensation should always be paid at the regular rate or whether overtime premiums may apply.

To answer that question, it is helpful to look beyond Massachusetts to how other courts have addressed similar disputes.

Washington State Supreme Court Takes a Stronger Stance

A significant and influential ruling came from the Washington State Supreme Court, which addressed unpaid meal break violations involving nurses at Sacred Heart Medical Center.

In that case, nurses frequently worked through their scheduled meal breaks due to staffing shortages and patient care demands. Despite this, the hospital automatically deducted meal periods from their pay. The nurses argued that this unpaid work should not only be compensated, but compensated at the overtime premium rate when applicable.

The Washington Supreme Court agreed.

Why Overtime Pay Matters for Missed Meal Breaks

The Court held that nurses who worked through their meal breaks were entitled to overtime pay, not merely straight-time compensation. This distinction is critical. Paying only the regular hourly rate for unpaid meal break work could create a perverse incentive for employers.

The Court reasoned that if employers are allowed to pay only straight-time wages for missed meal breaks, they may be encouraged to understaff workplaces, knowing they can rely on employees to work through breaks without facing meaningful financial consequences. Overtime premiums, on the other hand, serve as a deterrent and promote proper staffing levels.

By requiring overtime pay, the Court reinforced the principle that labor laws exist not only to compensate employees fairly, but also to influence employer behavior in a way that protects worker health, safety, and well-being.

Automatic Deductions Can Create Systemic Wage Violations

Automatic meal break deductions are not inherently illegal. However, they become unlawful when employers fail to ensure that employees actually receive uninterrupted breaks—or fail to provide a reliable way for employees to report missed or interrupted meal periods.

When employees regularly work through breaks without compensation, these deductions can result in systemic wage violations, affecting large groups of workers over extended periods. In industries such as healthcare, manufacturing, retail, and logistics, these practices can add up to thousands of dollars in unpaid wages per employee.

Courts are increasingly scrutinizing these systems, especially when employers place the burden on employees to “opt out” of deductions rather than ensuring compliance upfront.

What Employees Should Know About Their Rights

If you are required to work during your meal breaks while your employer automatically deducts that time from your pay, you may be entitled to recover unpaid wages—and potentially overtime compensation. The exact remedies available depend on state law, the nature of your work, and how frequently these violations occur.

Importantly, employers cannot avoid liability simply by labeling a break as “unpaid” if employees are expected to remain on duty, respond to work demands, or continue performing job-related tasks.

When to Seek Legal Help

Wage and hour violations are often difficult for employees to challenge alone, particularly when employers rely on automated payroll systems or company-wide policies. Consulting an attorney experienced in employment and wage law can help you understand your rights, evaluate potential claims, and determine whether you may be entitled to back pay or other remedies.

Final Thoughts

Courts across the country are increasingly recognizing that unpaid meal break work is not a minor payroll issue—it is a serious labor law violation with real consequences for workers. Decisions like those from the Massachusetts federal court and the Washington State Supreme Court highlight a growing judicial emphasis on fair compensation and employer accountability.

If you find yourself regularly working through promised meal breaks while your wages are automatically deducted, it is important to take action. You have rights—and the law may be on your side.