Anderson v. Mount Clemens Pottery Co
In Anderson v. Mount Clemens Pottery Co., 328 U.S. 680, 689, 66 S.Ct. 1187, 90 L.Ed. 1515 (1946)the Supreme Court held that otherwise compensable preliminary and postliminary activities are not included in calculating hours worked in a week if the period of time spent on an activity is so "insubstantial and insignificant" that it ought not be included in the work week. 328 U.S. at 693, 66 S.Ct. 1187.
"A few seconds or minutes of work beyond the scheduled working hours ... may be disregarded. Split-second absurdities are not justified.... It is only when an employee is required to give up a substantial measure of his time and effort that compensable working time is involved." Id. at 692, 66 S.Ct. 1187.