Michael Anagnos v. The Nelson Residence, Inc.
16-16401
| 11th Cir. | Jan 10, 2018Background
- Anagnos lived at the Haven for Divine Love (property owned by The Nelsen Residence, Inc.) and performed cleaning, landscaping, and repair work after moving in; he later stopped paying rent when Valenta (Residence president) suspended his rent and refused to pay him.
- Anagnos sued The Residence and Jerome Valenta seeking unpaid minimum wages and retaliation remedies under the Florida Constitution (Art. X, § 24) and the Florida Minimum Wage Act, alleging they were his employer under FLSA definitions.
- At trial, defendants presented evidence the Haven operated as an apartment/low-income elderly housing and did not provide care services that would qualify it as a residential care facility under FLSA coverage rules.
- The district court instructed the jury that Anagnos could recover Florida minimum wages only if the employer was covered under the FLSA (i.e., operating a residential care facility for purposes relevant to enterprise coverage).
- The jury answered a special interrogatory “no” to whether The Residence and Valenta operated a residential care facility; the district court entered judgment for defendants on the minimum-wage claim.
- Anagnos appealed, arguing the Florida Wage Amendment creates an independent state minimum-wage right not conditioned on FLSA coverage; the Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a plaintiff seeking Florida constitutional minimum wages must prove FLSA coverage | Anagnos: Art. X, § 24 is self-executing and creates a state minimum-wage right independent of FLSA coverage | The Residence/Valenta: Art. X, § 24 incorporates FLSA definitions and guidance; state law requires FLSA-type coverage | Held: Art. X, § 24 adopts FLSA meanings and guidance; plaintiff must prove FLSA coverage to recover state minimum wages |
| Whether the district court correctly instructed the jury to decide FLSA-based coverage first | Anagnos: Court should not condition state remedy on FLSA coverage | Defendants: Proper to instruct jury per constitutional text and implementing Wage Act | Held: Instruction and special interrogatory accurately reflected law; no error |
Key Cases Cited
- Burchfield v. CSX Transp., 636 F.3d 1330 (11th Cir.) (standard for reviewing jury-instruction denials)
- McNely v. Ocala Star-Banner Corp., 99 F.3d 1068 (11th Cir.) (review of special interrogatory/verdict-form issues)
- Am. Bankers Ins. Grp. v. United States, 408 F.3d 1328 (11th Cir.) (textualist approach: give words their plain meaning)
- BedRoc Ltd., LLC v. United States, 541 U.S. 176 (U.S. Supreme Court) (start and end with statutory text when unambiguous)
- Advisory Op. to Att’y Gen. re Minimum Wage, 880 So. 2d 636 (Fla.) (Florida Supreme Court recognizing Wage Amendment’s incorporation of FLSA body of law)