Amaya v. Logo Enterprises, LLC
251 F. Supp. 3d 196
D.D.C.2017Background
- Plaintiff Tomas Lemus Amaya worked as a kitchen hand at Pollo Granjero (owned/operated by Logo Enterprises, LLC) from 2009 until about October 21, 2015; he alleges averaging 83 hours/week and receiving biweekly flat pay well below DC minimum wages.
- Amaya sued under the FLSA and the D.C. Wage Payment and Collection Law (DCWPCL) on Jan. 5, 2016 for unpaid minimum and overtime wages, liquidated damages, attorneys’ fees, and costs.
- Defendants (Logo Enterprises and owner Juan Loyola) were properly served but did not respond; the Clerk entered default and Amaya moved for default judgment.
- Amaya submitted an affidavit with detailed hour and pay calculations showing $82,198.89 in unpaid wages for Jan. 1, 2013–Oct. 21, 2015; court independently confirmed the wage calculation.
- The court found Loyola exercised operational control (hiring, scheduling, pay, supervision) and therefore was individually liable under the FLSA/DCWPCL; as a result, both Logo Enterprises and Loyola were held liable.
- The court calculated liquidated damages according to the applicable temporal application of the DC treble-damages provisions and awarded attorneys’ fees based on the USAO Laffey Matrix; total judgment entered was $291,121.74.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Employer liability under FLSA/DCWPCL for unpaid minimum and overtime wages | Amaya: Logo Enterprises failed to pay required DC minimum wages and overtime for ~83-hr weeks, owing unpaid wages. | (No response) Default; no contest. | Court accepted Amaya’s well-pleaded allegations and found Logo Enterprises liable. |
| Individual liability of owner (Loyola) | Amaya: Loyola owned/operated the restaurant, hired/supervised Amaya, set schedule and pay — thus an "employer." | (No response) | Court found Loyola exercised operational control and is individually liable under FLSA/DCWPCL. |
| Calculation of unpaid wages and overtime | Amaya: Provided affidavit showing hours, pay, and computed unpaid wages totaling $82,198.89. | (No response) | Court independently verified and adopted the $82,198.89 unpaid-wages figure. |
| Liquidated damages (amount and applicable time periods) | Amaya: Sought treble liquidated damages for much of the period, but misidentified effective dates. | (No response) | Court applied correct temporal sequence for DC treble provision and emergency act; awarded $200,261.25 in liquidated damages. |
| Attorney's fees and rates | Amaya: Sought fees based on submitted hours and Laffey rates (asked for higher LSI rates). | (No response) | Court awarded fees using USAO Laffey Matrix rates, reducing the requested amount to $8,181.60. |
Key Cases Cited
- Ventura v. L.A. Howard Constr. Co., 134 F. Supp. 3d 99 (D.D.C. 2015) (default-judgment damages procedures and DCWPCL interpretation)
- Boland v. Elite Terrazzo Flooring, Inc., 763 F. Supp. 2d 64 (D.D.C. 2011) (default establishes liability for well-pleaded allegations)
- Ventura v. Bebo Foods, Inc., 738 F. Supp. 2d 1 (D.D.C. 2010) (individual employer liability factors: operational control, hiring/firing, pay and scheduling)
- Guevara v. Ischia, Inc., 47 F. Supp. 3d 23 (D.D.C. 2014) (operational control as basis for individual liability under FLSA)
- Ruffin v. New Destination, 800 F. Supp. 2d 262 (D.D.C. 2011) (corporate officer joint-and-several liability under FLSA)
- Salazar ex rel. Salazar v. District of Columbia, 809 F.3d 58 (D.C. Cir. 2015) (discussion of Laffey Matrix rates)
- Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir. 2015) (standards for proving prevailing community rates for fee awards)
- Blum v. Stenson, 465 U.S. 886 (U.S. 1984) (lodestar method: reasonable hours × reasonable rate)
- Driscoll v. George Washington Univ., 55 F. Supp. 3d 106 (D.D.C. 2014) (mandatory attorneys’ fees under FLSA for prevailing plaintiffs)