The U.S. Supreme Court case Steiner et al., doing business as Cumberland Battery Manufacturing Co., v. Mitchell, Secretary of Labor, 1955 revolved around the interpretation and application of the Fair Labor Standards Act (FLSA). The plaintiffs were employees at a battery manufacturing plant who were required to shower and change clothes both before and after their shifts due to exposure to harmful chemicals during work hours. They argued that this time should be considered part of their compensable workday under FLSA. The defendant, the Secretary of Labor, disagreed stating these activities fell outside regular working hours hence not payable under FLSA provisions. However, in its ruling, the Supreme Court sided with the workers holding that these activities are an integral part of principal activities performed by them for which they must be compensated accordingly.

In the dissenting opinion for Steiner v. Mitchell, Justice Reed argued that the majority's interpretation of "principal activities" under the Fair Labor Standards Act was too broad and inconsistent with Congress' intent. He contended that changing clothes and showering should not be considered integral parts of an employee's job unless it is a requirement explicitly stated in their contract or if failing to do so would prevent them from adequately performing their duties. In his view, these activities were more akin to preliminary tasks like commuting which are generally not compensated under federal law. Furthermore, he expressed concern about potential abuse by employees who might unnecessarily prolong such activities in order to receive additional pay.