Armour v. Wantock
In Armour v. Wantock, 323 U.S. 126, 65 S.Ct. 165, 89 L.Ed. 118 (1944), plaintiffs had to remain on call on the employer's premises for fifteen hours after their regular shifts as auxiliary firemen.
The Supreme Court affirmed a lower court holding that the time spent eating and sleeping did not constitute work time, but that all waiting or on-call time should be compensated under the Fair Labor Standards Act (FLSA) because "time spent lying in wait for threats to the safety of the employer's property may be treated by the parties as a benefit to the employer." Id. at 133, 65 S.Ct. at 168.