On September 14, 2017, the Tenth Circuit Court of Appeals provided employers with further guidance regarding the compensability of pre-shift tasks under the Fair Labor Standards Act (“FLSA”). Specifically, in Jimenez, Bustillos, et al. v. Board of County Commissioners of Hidalgo County (Case No. 15-2213, Sept. 14, 2017), an unpublished decision, the court held that emergency 911 dispatchers who are required by the employer to participate in mandatory pre-shift briefings for five minutes before each shift must be compensated for that time.