Peters v. Early Healthcare Giver, Inc.
439 Md. 646
| Md. | 2014Background
- Peters worked as a certified nursing assistant for EHCG from April 2008 to April 2009; she consistently worked 119 hours biweekly at $12/hour for all hours including overtime.
- EHCG paid Peters $12/hour, with $4 of the Medicaid payment routed to EHCG under a federal program.
- Peters claimed EHCG wrongfully withheld overtime wages under WPCL and WHL; the trial court denied overtime on preemption grounds.
- On remand, Peters sought unpaid overtime and treble damages under WPCL § 3-507.2(b); the circuit court awarded unpaid wages but denied enhanced damages.
- The Court of Special Appeals remanded for consideration of enhanced damages if no bona fide dispute existed; this Court granted certiorari to address three questions about WPCL overtime, bona fide disputes, and treble damages.
- The Court ultimately held overtime wages are recoverable under WPCL, rejected a mandatory enhanced damages award absent a bona fide dispute, and held the WPCL total damages cap is three times the unpaid wage, remanding for further proceedings on enhanced damages only if a bona fide dispute was absent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are overtime wages recoverable under WPCL? | Peters relies on Friolo I to show WPCL covers overtime after termination. | EHCG argued federal preemption and exemptions under FLSA. | Yes; overtime wages are recoverable under WPCL. |
| Is it an abuse of discretion to deny enhanced damages when no bona fide dispute is claimed? | Peters contends no predicate finding of no bona fide dispute was made. | EHCG asserts discretion to deny enhanced damages when appropriate. | No; discretionary denial allowed, but remand required to address predicate finding. |
| Should WPCL treble damages be added to unpaid wages (quadruple total)? | Lees argues damages may be added to unpaid wages, creating quadruple damages. | Commissioner argues total damages are three times the unpaid wage, not in addition to it. | Total damages are three times the unpaid wage; not in addition to unpaid wages. |
Key Cases Cited
- Friolo v. Frankel, 373 Md. 501 (2003) (WPCL scope includes overtime claims post-termination)
- Programmers’ Consortium, Inc. v. Clark, 409 Md. 548 (2009) (no explicit predicate finding, enhanced damages may be denied)
- Barufaldi v. Ocean City, Md. Chamber of Commerce, Inc., 206 Md. App. 282 (2012) (liberal consideration of attorneys’ fees; relevance to discretionary awards)
- Admiral Mortgage & Realty Servs., Inc. v. Cooper, 357 Md. 533 (2000) (burden-shifting and discretionary principles for damages)
- Stevenson v. Branch Banking & Trust Corp., 159 Md. App. 620 (2004) (dispute over whether WPCL damages can exceed three times unpaid wages)
- Battaglia v. Clinical Perfusionists, Inc., 338 Md. 352 (1995) (WPCL remedial purpose and incentives for payment)