Maria Teresa Davila v. Maria Claudia Menendez
717 F.3d 1179
11th Cir.2013Background
- Davila worked as a nanny for the Menendezes from 2004 to 2010, with initial pay of $350/week later raised to $400/week.
- She worked long hours, alleged averages of 100 hours/week during 2004–2008 and 75–70 hours/week later, and claimed no proper recordkeeping or formal wage notices.
- The Menendezes paid in cash at times, did not sign a written contract, and Davila lived with the family during certain periods, raising wage- and recordkeeping concerns.
- Davila visited Canada in 2008, obtained Canadian resident status for Medicare, and returned to work in 2008; she was terminated in March 2010.
- Davila asserted federal minimum wage violations and Florida Constitution wage violations, seeking double damages and attorneys’ fees; the Menendezes denied willful violation.
- At trial, the jury found $33,025 in unpaid wages and the district court granted JMOL against Davila on willfulness and denied liquidated damages; this appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred in JMOL on willfulness | Davila contends evidence supported willful violation. | Menendezes argue lack of willfulness based on ignorance and no bad intent. | Judgment on willfulness reversed; jury must decide willfulness. |
| Whether Davila is entitled to liquidated damages | If willfulness is found, liquidated damages follow; otherwise not. | Good-faith defense may bar liquidated damages even without willfulness. | Remanded to determine liquidated damages after willfulness is re‑decided. |
Key Cases Cited
- McLaughlin v. Richland Shoe Co., 486 U.S. 128 (Supreme Court 1988) (willful violation includes knowledge or reckless disregard)
- Alvarez Perez v. Sanford-Orlando Kennel Club, Inc., 515 F.3d 1150 (11th Cir. 2008) (burden to prove willfulness by preponderance)
- Rodriguez v. Farm Stores Grocery, Inc., 518 F.3d 1259 (11th Cir. 2008) (distinct burdens for willfulness and good faith)
- Dybach v. Fla. Dep’t of Corr., 942 F.2d 1562 (11th Cir. 1991) (good-faith defense in liquidated damages analysis)
- Thorne v. All Restoration Servs., Inc., 448 F.3d 1264 (11th Cir. 2006) (de novo/review standard for some legal questions; weigh evidence carefully)
- Mich. Millers Mut. Ins. Corp. v. Benfield, 140 F.3d 915 (11th Cir. 1998) (standard for judgment as a matter of law; consider conflicting evidence)
- EEOC v. Massey Yardley Chrysler Plymouth, Inc., 117 F.3d 1244 (11th Cir. 1997) (limits on willfulness and evidence evaluation in wage cases)