Maria Eugenia Blanco v. Anand Adrian Samuel
91 F.4th 1061
11th Cir.2024Background
- Maria Blanco worked as a nanny and housekeeper for Anand Samuel and Dr. Lindsey Finch for roughly three years, typically working 79 hours a week in shifts, but not residing at the parents' home outside those hours.
- Blanco maintained a separate residence with her aunt, visited the parents' house only for shifts, and was always on duty during her time there.
- Blanco was paid for all 79 hours she worked, but claimed entitlement to overtime pay for hours exceeding 40 per week under the Fair Labor Standards Act (FLSA).
- The parents argued that Blanco was exempt from overtime under the FLSA's live-in domestic worker exemption, asserting she “resided” in their home because she slept there while on duty.
- The district court granted summary judgment for the parents, holding Blanco was exempt; the issue of whether the parents were actually employers remained disputed.
- On appeal, the Eleventh Circuit reviewed summary judgment de novo and reconsidered whether Blanco met the statutory definition of a "live-in" employee and whether a fact issue existed regarding employer status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Blanco exempt from FLSA overtime as a live-in domestic worker? | Blanco did not “reside” at the parents’ house, only worked long shifts, and maintained a separate home. | Blanco was exempt as she worked and slept overnight in the parents’ house across five consecutive nights per week. | No exemption; Blanco did not "reside" there and is entitled to overtime pay. |
| Does sleeping at the employer’s home during shifts constitute “residing”? | Sleeping during work is not residence; she was always on duty and did not have personal time or space. | Sleeping at the house and keeping some belongings there means "residing" under the FLSA. | Sleeping during shifts, without control over space/time, does not amount to "residing." |
| Do Department of Labor regulations/preamble interpretations control the result? | Statutory text is clear; agency guidance is only persuasive, not controlling. | DOL preamble supports exemption for workers who spend five nights at the home. | Statutory text is unambiguous; regulations/preamble do not change the result, and even if they did, Blanco does not meet "reside" definition. |
| Are the parents legally considered Blanco’s employer under the FLSA? | Parents exercised economic control and direct supervision, satisfying "employer" status. | All employment and supervision was handled by third-party LLCs, not by the parents. | Fact dispute exists; remanded for trial to determine employer status. |
Key Cases Cited
- Long Island Care at Home, Ltd. v. Coke, 551 U.S. 158 (meaning and history of FLSA domestic worker amendments and exemptions)
- Encino Motorcars, LLC v. Navarro, 138 S. Ct. 1134 (FLSA exemptions get a fair—not narrow—interpretation)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
- Nationwide Mut. Ins. Co. v. Darden, 503 U.S. 318 (economic reality test for employment)
- Rutherford Food Corp. v. McComb, 331 U.S. 722 (breadth of FLSA definition of "employ")
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment—jury functions for credibility/inference)