On January 27, 2014, in Sandifer v. United States Steel Corp., the U.S. Supreme Court forged a middle ground on the meaning of the term "changing clothes" in section 3(o) of the Fair Labor Standards Act. The outcome of this case will have a significant impact on unionized employers in a wide variety of industries where workers change in and out of protective and/or sanitary clothing at the start and end of their workdays. However, the Supreme Court's opinion also leaves some unanswered questions on the compensability of clothes changing under section 3(o). For more on this significant decision, please read Littler's ASAP, Supreme Court Finds Middle Ground on Definition of “Clothes” Under the FLSA, by Tammy McCutchen and William Allen, who wrote an amicus brief to the Supreme Court in support of U.S. Steel Corp. on behalf of the Grocery Manufacturers Association.