Supreme Court of Maryland
Martinez v. Amazon
July 3, 2025
Summary
The Supreme Court of Maryland answered a certified question affirmatively and held that the de minimis doctrine applies to claims under the Maryland Wage and Hour Law and Maryland Wage Payment and Collection Law. The Court reasoned that the Maryland wage statutes substantially parallel the federal wage statute, whose original framework included the doctrine, and that the statutory phrase requiring payment of all compensation that is due does not determine what compensation is due. The Court limited its decision to whether the doctrine applies and did not define its specific scope.