Al-Quraan v. 4115 8th St. NW, LLC
123 F. Supp. 3d 1
D.D.C.2015Background
- Plaintiff Murad Al‑Quraan sued Loftstel (4115 8th St. NW, LLC) under the FLSA and D.C. Minimum Wage Act for unpaid minimum wages, liquidated damages, and attorneys’ fees.
- Court entered default judgment against Loftstel; entry of final judgment was delayed pending claims against co‑defendants, who were later dismissed.
- Plaintiff submitted a shift-by-shift chart and testified that he worked either 232 hours (exhibit) or “approximately 216 hours” (complaint); court credited the complaint’s 216 hours due to the unexplained discrepancy.
- Plaintiff received only lodging (payment in kind); employer offered no proof to claim a lodging credit against wages.
- Court found meal breaks and alleged “on‑call” time were not bona fide unpaid breaks given testimony that Plaintiff remained responsible for work during those periods.
- Court held an evidentiary hearing on damages and awarded unpaid wages, liquidated damages, and attorneys’ fees/costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Plaintiff is entitled to unpaid minimum wages for hours worked | Al‑Quraan asserted he worked the hours listed and was unpaid except for lodging | Kuenzel/Loftstel argued Plaintiff took regular 30‑minute meal breaks and some late shifts were on‑call (not compensable) | Court credited 216 hours in complaint; meal breaks/on‑call were compensable because Plaintiff remained responsible for duties |
| Whether employer may offset wages for lodging provided | Plaintiff argued no offset; employer offered no proof of any lodging credit | Employer did not present evidence to support a statutory lodging credit | Court denied any lodging credit; full minimum wage owed |
| Whether liquidated damages are owed under FLSA | Plaintiff sought liquidated damages equal to unpaid wages | Defendant offered no showing of good faith to avoid liquidated damages | Court awarded liquidated damages equal to unpaid wages (double recovery) |
| Reasonableness of attorneys’ fees and hourly rate | Counsel sought fees based on billing records and $320/hr rate | No opposing challenge to hours; rate slightly above Laffey matrix but justified by experience | Court found $320/hr reasonable, awarded $3,619 in fees and costs |
Key Cases Cited
- Al‑Kazemi v. Gen. Acceptance & Inv. Corp., 633 F. Supp. 540 (D.D.C. 1986) (defaulting defendant concedes well‑pleaded liability allegations; court may determine damages)
- Flynn v. Mastro Masonry Contractors, 237 F. Supp. 2d 66 (D.D.C. 2002) (court may use affidavits/documentary evidence or hold hearing to determine damages on default)
- Marroquin v. Country Choice, LLC, 70 F. Supp. 3d 1 (D.D.C. 2014) (FLSA and DCMWA require unpaid wages, liquidated damages, and fees)
- Pleitez v. Carney, 594 F. Supp. 2d 47 (D.D.C. 2009) (awarding remedies under FLSA/DCMWA)
- Summers v. Howard Univ., 127 F. Supp. 2d 27 (D.D.C. 2000) (distinguishing compensable work time from bona fide meal breaks)
- Blum v. Stenson, 465 U.S. 886 (1984) (reasonable hourly rates measured by prevailing community rates)
- Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (endorsing Laffey matrix as starting point for fee awards)
- Myers v. Copper Cellar Corp., 192 F.3d 546 (6th Cir. 1999) (employer bears burden to prove credit for lodging against wages)