Mario Amaya v. DGS Construction, LLC, 22-1232

DGS Construction, LLC (doing business as Schuster) subcontracted on the MGM Grand project; Whiting-Turner had a Project Labor Agreement (PLA) and a Project Manual with an S.3 wage schedule mirroring DLLR (state) rates.
S.3 listed a Basic Hourly Rate and a Fringe Benefit Payment (paid only where workers took cash in lieu of in-kind benefits) but did not state whether fringe payments applied to overtime hours; Schuster paid no fringe on overtime.
Mario Amaya and Jose Gonzalez (and a proposed class of ~1,600 workers who took cash in lieu) sued alleging violations of the Maryland Wage Payment and Collection Law (MWPCL) and unjust enrichment; the district court granted summary judgment on the MWPCL claim but allowed the unjust enrichment claim to proceed to trial.
At trial the jury found Schuster unjustly enriched by withholding fringe payments on overtime; the district court denied Schuster’s Rule 50 motions; Schuster appealed, and plaintiffs conditionally cross-appealed the MWPCL summary judgment.
The Fourth Circuit affirmed: it held the evidence supported unjust enrichment, and it found no abuse of discretion in the district court’s evidentiary rulings or jury instructions; the panel therefore left the MWPCL summary-judgment ruling undisturbed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for unjust enrichment (elements: benefit, knowledge, inequity)	Amaya/Gonzalez: class conferred a monetary benefit by working without overtime fringe; Schuster knew/benefitted and it is inequitable to retain savings	Schuster: no legal entitlement to overtime fringe; evidence insufficient to prove the three elements	Court: Affirmed—viewing evidence in plaintiffs’ favor, there was sufficient proof of benefit, Schuster’s knowledge/appreciation, and inequity to support verdict
Jury instructions & motion in limine (admission of S.3 testimony)	Plaintiffs: instructions tracked Maryland unjust-enrichment law; S.3 is probative of expectations and inequity	Schuster: jury charge was incomplete (didn’t account for at-will employment); S.3 testimony should be excluded as contradictory to summary-judgment ruling	Court: No abuse of discretion—instructions were correct and covered requested points; S.3 testimony was admissible to show expectations and equity
Cross-appeal on MWPCL summary judgment	Plaintiffs (conditional): district court erred in granting summary judgment on MWPCL	Schuster: summary judgment proper because no express promise under Project Manual incorporated state-law obligations	Court: Did not reach merits because unjust-enrichment verdict was affirmed; therefore summary-judgment ruling stands

Hill v. Cross Country Settlements, LLC, 936 A.2d 343 (Md. 2007) (sets Maryland unjust-enrichment elements and principles)
County Comm’rs of Caroline Cnty. v. J. Roland Dashiell & Sons, Inc., 747 A.2d 600 (Md. 2000) (unjust enrichment as remedy where no enforceable contract)
Dolan v. McQuaide, 79 A.3d 394 (Md. Ct. Spec. App. 2013) (unjust-enrichment analysis where defendant’s benefit and plaintiff’s services disputed)
Amaya v. DGS Constr., LLC, 278 A.3d 1216 (Md. 2022) (state-court decision cited regarding entitlement arguments)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (deference to jury credibility determinations)
Ward v. AutoZoners, LLC, 958 F.3d 254 (4th Cir. 2020) (standards for refusing a requested jury instruction)
First Union Commercial Corp. v. GATX Capital Corp., 411 F.3d 551 (4th Cir. 2005) (standard of review for Rule 50 motions)