Maria Teresa Davilav.Maria Claudia Menendez, Et Al
Maria Teresa Davila worked as a live-in nanny for Maria Claudia and Rudolfo Menendez and alleged that she routinely worked long hours for less than the federal minimum wage. After a trial, a jury awarded her $33,025 in unpaid wages, but the district court ruled that the employers had not willfully violated wage laws and denied liquidated damages. The Eleventh Circuit vacated that ruling. Evidence that the employers knew or should have known about minimum-wage requirements, paid Davila partly in cash, failed to record her hours, and did not investigate their legal obligations could permit a reasonable jury to find willfulness. The district court therefore should not have removed that issue from the jury. The court also held that the decision on liquidated damages had to be reconsidered after the willfulness question was resolved. Willfulness and good faith involve different burdens: the employee must prove willfulness, while the employer must prove an honest and objectively reasonable effort to comply before liquidated damages may be denied. The judgment was vacated and remanded for further proceedings, including a new jury determination on willfulness.
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