Falaiye v. CCA Academic Resources, LLC, 8:16-cv-02887

Plaintiff Akintola Falaiye was hired in Dec 2015 by CCA Academic Resources (Capitol Christian Academy) to teach; he worked ~500 hours from Dec 2015–Apr 2016 and received $1,500 in two payments.
Plaintiff alleged CCA failed to provide pay records, denied requests for written salary documentation, and did not pay agreed compensation; he resigned in April 2016.
Plaintiff sued under the FLSA, Maryland Wage and Hour Law (MWHL), and Maryland Wage Payment and Collection Law (MWPCL). Service and employer-identity issues delayed an initial default judgment.
Plaintiff withdrew claims against individual defendant Van Whitfield and proceeded only against CCA; CCA did not answer or defend after proper service was shown.
The court accepted Plaintiff’s factual allegations as true for liability purposes and found CCA an "employer" under the applicable economic‑reality test.
The court concluded CCA violated the FLSA, MWHL, and MWPCL and entered default judgment against CCA, awarding wages and liquidated damages (but not MWPCL treble damages).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper service on CCA	Service was effected by delivering summons/complaint to registered agent/principal (Whitfield)	No response; did not dispute service	Service sufficiently proved; default entered against CCA
Whether Whitfield is an employer	Initially alleged Whitfield was an employer	Plaintiff later voluntarily dismissed Whitfield; no defense from Whitfield	Whitfield dismissed; only CCA remained defendant
Whether CCA is an "employer" under FLSA/MWHL (economic‑reality)	Falaiye worked for, was hired by, and expected pay from CCA; CCA controlled employment relationship	No defense; employer could have raised white‑collar exemption (teachers) but did not	CCA qualifies as employer under economic‑reality test; court accepts coverage for default judgment
Whether wages were unpaid and remedies (FLSA/MWHL/MWPCL)	Worked 500 hrs; paid $1,500; claims unpaid wages plus liquidated/treble damages	No response; potential FLSA professional exemption not asserted	CCA violated MWHL and MWPCL; court awards unpaid wages ($2,625 under MWHL) and FLSA liquidated damages ($2,125); total $4,750; declines treble MWPCL award and awards FLSA liquidated damages instead

Ryan v. Homecomings Fin. Network, 253 F.3d 778 (4th Cir.) (on treating well‑pleaded allegations as true in default judgments)
Auer v. Robbins, 519 U.S. 452 (U.S.) (deference and DOL rulemaking authority re: white‑collar exemptions)
Schultz v. Capital Int’l Sec., Inc., 466 F.3d 298 (4th Cir.) (economic‑reality test for employer status)
Dejesus v. HF Mgmt. Servs., LLC, 726 F.3d 85 (2d Cir.) (employer bears burden of proving FLSA exemptions)
Eriline Co. S.A. v. Johnson, 440 F.3d 648 (4th Cir.) (courts should not raise affirmative defenses sua sponte)
Lawbaugh v. S.E.C., 359 F. Supp. 2d 418 (D. Md.) (default judgment appropriate when party is unresponsive)
Jacobson v. Comcast Corp., 740 F. Supp. 2d 683 (D. Md.) (factors for economic‑reality/employer status)
Agora Fin., LLC v. Samler, 725 F. Supp. 2d 491 (D. Md.) (court must determine whether unchallenged allegations state a cause of action)