In Cruz, et al. v. Unilock, in Illinois State Court, the plaintiffs alleged that the defendant’s time rounding policies improperly deducted work time from their weekly payroll. The plaintiffs, who were hourly manufacturing workers, contended that they routinely punched in before their start of shift, but were paid from rounded time punches that deducted the pre-shift time.

They also alleged that the defendant’s time system also routinely shorted time when they punched out. The defendant argued that the plaintiffs were not always working when they time punched outside of their scheduled work time. In the project, we studied the alleged impact of the defendant’s time rounding policies and the allegations of off-the-clock work.

In our analysis, we studied millions of individual time and payroll records for the plaintiffs over a ten year period. We also prepared and administered several surveys of the plaintiffs. We prepared several reports that provided insights on the commonality and typicality of the potential class. Dr. Dwight Steward testified at deposition regarding the plaintiffs’ allegations and potential economic damages. The case settled before trial.