Juan Andres Rodriguez v. Gold Star, Inc., 858 F.3d 1368

Juan Rodriguez worked as a valet parker in Miami Beach (Apr. 1, 2012–Nov. 15, 2014), averaging ~100 hours/week; he was paid straight pay but not overtime premium for hours over 40.
Rodriguez sued his employers under the FLSA, seeking overtime based on enterprise coverage under the statute’s “handling clause” (29 U.S.C. § 203(s)(1)(A)(i)).
The parties agreed Rodriguez handled cars that "have been moved in or produced for commerce," and that the employer met the $500,000 annual gross volume threshold. The sole disputed question was whether the cars are "materials."
The district court granted defendants’ summary judgment and denied Rodriguez’s motion for reconsideration; Rodriguez appealed only the enterprise-coverage/"materials" issue.
The Eleventh Circuit had previously interpreted "materials" in Polycarpe v. E&S Landscaping, concluding "materials" are distinct from "goods" and are items (tools/articles) necessary to the employer’s business operations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether cars parked by valet are "materials" under § 203(s)(1)(A)(i)	Rodriguez: The cars he handles are "materials," bringing employer within enterprise coverage	Defendants: The cars are customers’ goods, not employer’s materials, so enterprise coverage does not apply	Cars are "goods," not "materials;" ultimate-consumer exception excludes them from coverage; summary judgment for defendants affirmed

Polycarpe v. E & S Landscaping Serv., Inc., 616 F.3d 1217 (11th Cir. 2010) (defines "materials" as tools/articles necessary for doing or making something and distinguishes "materials" from "goods")
Polycarpe v. E & S Landscaping Serv., Inc., 821 F. Supp. 2d 1302 (S.D. Fla. 2011) (on remand, district court applied Polycarpe and found employer vehicles were "materials")