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On November 25, 2009, the 7th Circuit Court of Appeals ("COA"), in Musch v. Domtar Industries, held that employees' daily post-shift activities of changing clothes and showering due to potential chemical exposure in employer's paper mill was NOT so integral and indispensable to employment that it was subject to overtime compensation under the FLSA. 

On Industry Week, it was reported that Tyson Foods, the poultry producer, was found in violation of the FLSA for failing to pay employees at an Alabama plant for activities required by the company. 

On October 1, 2009, a Multonomah County jury in Portland, Oregon, found Del Monte based in Florida had violated Oregon minimum wage laws for having its employees engaging in donning/doffing activities prior to and at the end of their shift and during lunch.