Dana Mohammadi v. Augustine Nwabuisi
605 F. App'x 329
5th Cir.2015Background
- Mohammadi worked as a licensed vocational nurse/case manager for Resource from June 2009–Oct 2010 and Nov 2011; she alleges unpaid overtime for work outside scheduled shifts.
- Resource had a written policy prohibiting overtime pay without prior authorization; Mohammadi did not obtain prior approval.
- District court granted Mohammadi partial summary judgment on FLSA liability, liquidated damages, and applied the three-year statute of limitations (willful violation); it awarded damages after a bench trial.
- Resource appealed the partial summary judgment (liability, liquidated damages, and limitations period) and contested the damages calculation.
- The Fifth Circuit affirmed summary judgment as to liability and liquidated damages but held genuine disputes of material fact exist on willfulness; it reversed the limitations-period ruling and remanded for further proceedings on that issue (and any resultant damage adjustment).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FLSA liability established | Mohammadi: she worked uncompensated overtime and Resource’s policy prevented pay | Resource: some activities were social; policy required prior approval for overtime | Liability summary judgment affirmed |
| Whether liquidated damages appropriate | Mohammadi: employer acted without valid defense to avoid liquidated damages | Resource: claimed good faith / reasonableness defenses | Liquidated-damages summary judgment affirmed |
| Applicable statute of limitations (2 yrs v. 3 yrs for willful violations) | Mohammadi: Resource acted willfully (policy, business longevity, prior suit) | Resource: disputed notice/willfulness; alleged beliefs about state client pay rules and lack of notice/legal advice | Reversed: genuine disputes of material fact on willfulness; trial required to decide 2 vs. 3 years |
| Damages calculation after bench trial | Mohammadi: damages based on three-year period awarded by district court | Resource: damages would be lower if two-year period applies; challenges to evidentiary rulings | Damages computation not reversed on record, but subject to modification if limitations period determined to be two years on remand |
Key Cases Cited
- McLaughlin v. Richland Shoe Co., 486 U.S. 128 (1988) (defines willfulness standard under FLSA and distinguishes negligence from willful conduct)
- Trans World Airlines, Inc. v. Thurston, 469 U.S. 111 (1985) (discusses standards bearing on employer liability under federal statutes)
- Mireles v. Frio Foods, 899 F.2d 1407 (5th Cir. 1990) (explains failure to seek legal advice and lack of notice as not necessarily establishing willfulness)
- Cox v. Brookshire Grocery Co., 919 F.2d 354 (5th Cir. 1990) (places burden on employee to prove willful FLSA violation for extended limitations period)
- Ikossi-Anastasiou v. Bd. of Supervisors of La. State Univ., 579 F.3d 546 (5th Cir. 2009) (employer knowledge or ignored complaints can support willfulness finding)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (sets summary judgment standard regarding genuine disputes of material fact)
- Rogers v. Bromac Title Servs., L.L.C., 755 F.3d 347 (5th Cir. 2014) (applies de novo review standard for summary judgment in Fifth Circuit)
- Gray v. Powers, 673 F.3d 352 (5th Cir. 2012) (addresses evidence-viewing standard on summary judgment)
- Green v. Adm’rs of Tulane Educ. Fund, 284 F.3d 642 (5th Cir. 2002) (standard of review for evidentiary rulings)
- Kona Tech. Corp. v. S. Pac. Transp. Co., 225 F.3d 595 (5th Cir. 2000) (review standards: clear error for factual findings, de novo for legal conclusions)