Martinez v. Asian 328, LLC
220 F. Supp. 3d 117
| D.D.C. | 2016Background
- Plaintiffs Eduardo Martinez, Erik Amaya, and Marlin Sanchez sued Asian 328, LLC and its owner Ling Chun Zheng under the FLSA and D.C. wage laws, alleging unpaid minimum and overtime wages for kitchen work at a D.C. restaurant.
- A jury found Defendants liable and returned week-by-week findings of hours worked and wages paid for each plaintiff; the jury did not calculate unpaid wages or damages.
- The Court solicited post-trial briefing on how to convert the jury’s factual findings (hours and payments) into monetary damages and received competing proposals.
- Plaintiffs asked the Court to apply arithmetic formulas using the applicable D.C. minimum wages (which changed during the relevant periods) and to use the lower weekly wage when an increase occurred mid-week; Defendants objected to the Court performing the mathematical calculation instead of the jury.
- The Court adopted Plaintiffs’ computational method, calculated unpaid wages for each plaintiff by comparing required pay (regular + 1.5x overtime) to amounts actually paid, and then applied D.C. law treble liquidated damages under the DCWPCL, resulting in judgments of $96,200.12 (Martinez), $43,055.08 (Amaya), and $16,091.28 (Sanchez).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court may compute damages using the jury’s factual findings rather than sending formulaic calculations to the jury | Court should apply arithmetic to jury’s findings to calculate unpaid wages using applicable minimum wages and overtime multiplier; use lower wage for weeks spanning an increase | Jury must perform any damages calculation; Seventh Amendment right to have jury perform full damage award | Court held no Seventh Amendment bar to court performing formulaic math; adopted plaintiffs’ computation method and calculated damages itself |
| Proper minimum-wage rate to apply when a statutory increase occurs mid-week | Use the lower minimum wage for the entire week when an increase occurs mid-week | Objected generally to court calculating damages but did not dispute this specific rule | Court adopted plaintiffs’ proposal to use the lower weekly minimum wage when a statutory increase fell mid-week |
| Measure of liquidated damages (FLSA vs DCWPCL) | Apply D.C. law first because it provides greater relief; treble unpaid wages under DCWPCL (not duplicative with FLSA) | Not contested in substance; defendants did not advocate alternative multiplier | Court applied DCWPCL treble liquidated damages in addition to unpaid wages and declined duplicate FLSA award |
| Procedure for attorney’s fees motion timing | Plaintiffs requested schedule to file fee application | No substantive opposition to scheduling | Court set deadlines for plaintiffs’ fee motion and defendant responses (fees to be filed by Dec. 20, 2016) |
Key Cases Cited
- Monroe v. FTS USA, LLC, 815 F.3d 1000 (6th Cir. 2016) (no Seventh Amendment right to a jury to perform purely formulaic mathematical damages calculations)
- Wallace v. FedEx Corp., 764 F.3d 571 (6th Cir. 2014) (court may render judgment as a matter of law for damages compelled by a legal rule or where calculation is not genuinely disputed)
- Ventura v. L.A. Howard Constr. Co., 134 F. Supp. 3d 99 (D.D.C. 2015) (apply more generous D.C. wage-law remedies before awarding federal duplicative relief)