AMAYA v. LOGO ENTERPRISES, LLC
1:16-cv-00009
D.D.C.May 4, 2017Background
- Plaintiff Tomas Lemus Amaya worked as a kitchen hand at Pollo Granjero (owned/operated by Logo Enterprises, LLC and owner Juan Loyola) until October 21, 2015, and alleges he worked ~83 hours per week for ~two years.
- Amaya sued under the FLSA and the D.C. Wage Payment and Collection Law (DCWPCL), claiming unpaid minimum wages and unpaid overtime for the period Jan 1, 2013–Oct 21, 2015.
- Defendants (Logo Enterprises and Loyola) were properly served but did not respond; the clerk entered default and Amaya moved for default judgment.
- Amaya submitted an affidavit detailing hours worked, pay received, and calculations of unpaid wages; Court independently verified unpaid wages of $82,198.89.
- Court found Loyola exercised operational control (hiring, supervision, pay, schedule) and thus is individually liable along with the company under FLSA/DCWPCL.
- Applying the time-varying DC liquidated-damages rules (including an emergency act window and later treble-damages provision), the Court calculated liquidated damages of $200,261.25 and awarded attorneys’ fees, costs, and expenses, for a total judgment of $291,121.74.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Liability under FLSA/DCWPCL | Amaya: Logo Enterprises and Loyola failed to pay minimum and overtime for hours worked; Loyola had operational control making him an employer | No response due to default | Court accepted well-pleaded allegations and held both Logo Enterprises and Loyola liable |
| Individual liability of owner | Amaya: Loyola hired/supervised/paid Amaya and ran operations, so individually liable | No response | Court held Loyola an employer with individual liability under FLSA/DCWPCL |
| Quantum of unpaid wages | Amaya: Affidavit shows 83-hr weeks, pay history; unpaid wages = $82,198.89 | No response | Court independently confirmed and adopted $82,198.89 unpaid wages |
| Liquidated damages calculation under DCWPCL/FLSA | Amaya: Sought liquidated damages (variously calculated) including treble for much of the period | No response | Court applied statutory timeline (including emergency act window and later treble provision) and awarded $200,261.25 in liquidated damages |
| Attorneys’ fees and rate | Amaya: Seeks fees based on hours worked and Laffey Matrix rates | No response | Court found hours reasonable, applied USAO Laffey Matrix rates, and awarded $8,181.60 in fees plus costs and expenses |
Key Cases Cited
- Ventura v. L.A. Howard Constr. Co., 134 F. Supp. 3d 99 (D.D.C. 2015) (default-judgment and damages procedures under FLSA/DCWPCL)
- Boland v. Elite Terrazzo Flooring, Inc., 763 F. Supp. 2d 64 (D.D.C. 2011) (default establishes liability for well-pleaded allegations)
- Fanning v. Permanent Sol. Indus., Inc., 257 F.R.D. 4 (D.D.C. 2009) (use of affidavits/documentation to determine damages on default)
- Ruffin v. New Destination, 800 F. Supp. 2d 262 (D.D.C. 2011) (corporate officer with operational control is an employer under FLSA)
- Salazar ex rel. Salazar v. District of Columbia, 809 F.3d 58 (D.C. Cir. 2015) (discussion of Laffey Matrix for attorneys’ fees)
- Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir. 2015) (burden to show fee rates conform to prevailing community rates)
- Blum v. Stenson, 465 U.S. 886 (1984) (lodestar method: hours reasonably expended times reasonable hourly rate)