Not legal advice — for informational purposes only.
On-Call & Hours Worked

Service & commerce

Retail managers & shift leads: on-call scheduling

The short answer

On-call retail shifts that require you to call in and hold the day open are compensable when the restrictions prevent using the time for yourself under 29 C.F.R. § 785.17, and in California an on-call shift can trigger reporting-time pay even if you are never used: Ward v. Tilly's, Inc., 31 Cal. App. 5th 1167 (2019).

Call-in shifts and reporting-time pay

The California Court of Appeal held in Ward v. Tilly's, Inc., 31 Cal. App. 5th 1167 (2019), that employees required to call in two hours before an on-call shift “report for work” and are owed reporting-time pay under IWC Wage Order 7-2001 § 5.

Assistant managers and exempt status

Assistant managers who spend most of their time on sales-floor tasks generally do not meet the executive exemption in 29 C.F.R. § 541.100, and California requires more than half the time on exempt duties under Cal. Lab. Code § 515.

Off-the-clock closing work

Closing tasks, bank runs, and after-clock-out cleanup are hours worked under 29 C.F.R. § 785.11, and California rejects the de minimis defense for regular small increments under Troester v. Starbucks Corp., 5 Cal. 5th 829 (2018).

Facts that usually decide these cases

  • Mandatory call-in before a scheduled on-call shift
  • Assistant managers doing mostly non-exempt work
  • Unpaid closing and bank-run time
  • Schedules that hold the whole day open

Weighed together under the framework of Owens v. Local No. 169, 971 F.2d 347 (9th Cir. 1992): Geographic restriction — how far you may travel while on call; Response time — how many minutes you have to answer or arrive; Call frequency — how often the phone actually rings; Personal interference — what the rotation stops you from doing; Trade or refusal rights — whether you can hand the shift off.

Frequently asked questions

Do I get paid if my on-call retail shift is cancelled?
In California, calling in for an on-call shift can trigger reporting-time pay under IWC Wage Order 7-2001 § 5 per Ward v. Tilly's, Inc., 31 Cal. App. 5th 1167 (2019). Federally, pay depends on whether the restrictions made the wait compensable under 29 C.F.R. § 785.17.
I'm an assistant manager on salary. Am I exempt?
Only if you actually meet the executive duties test in 29 C.F.R. § 541.100; in California more than half your time must be exempt work under Cal. Lab. Code § 515.

Keep reading

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General legal information, not legal advice. OvertimeLaw.ai is not a law firm. For advice on your situation, consult a licensed attorney in your state.