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Timekeeping & Attendance

Is time at a security gate and driving on site paid in California?

By the WeERM Editorial Team

Huerta v. CSI Electrical Contractors (2024) held time waiting for and undergoing a mandatory vehicle security check is compensable even without leaving the car, and that travel from a security gate is paid where the gate is the first place the employee's presence is required for reasons beyond site access.

This decision extends the control principle from Frlekin's bag checks to the perimeter of a large worksite, and it matters most to construction, agriculture, logistics and any site where entry is controlled.

The first holding is straightforward: time spent waiting for and undergoing an employer-mandated vehicle inspection is hours worked. The employee cannot leave, cannot proceed, and is subject to the employer's direction throughout — the fact that they remained seated in their own vehicle does not change that.

The second holding is the one that surprises employers. Where the security gate is the first location at which the employee's presence is required for an employment-related reason beyond merely accessing the site, the subsequent on-site travel becomes employer-mandated travel and is compensable.

The court also drew the limit. Ordinary rules imposed during a commute — obeying speed limits, staying on a designated route — do not by themselves convert the commute into hours worked. What converts it is a requirement that serves the employer's purposes beyond getting the employee to work.

Reviewed 2026-08-10 by the WeERM team. Informational only, not legal advice. California rules change; confirm against the current source before acting.