Robinson v. Roberts Hotels Management Detroit, LLC, 661 F. App'x 890

Stephen Robinson worked as a non-exempt maintenance worker for Roberts Hotels Management Detroit (RHMD) from Sept. 24, 2012 to July 10, 2014 and later sued for unpaid overtime under the FLSA.
RHMD did not contemporaneously record Robinson’s hours because it had classified him as salaried at the time; RHMD later conceded he was non-salaried for FLSA purposes.
Robinson claimed he worked an average of 52 hours per week and offered his own testimony, his wife’s testimony, and handwritten work notes as proof.
The magistrate judge found Robinson’s and his wife’s testimony not credible and found the notes incomplete, often illegible, and silent as to when shifts ended or whether managers requested overtime.
The magistrate concluded Robinson failed to prove by a preponderance of the evidence that he performed uncompensated overtime; the district court’s judgment was affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Robinson proved he worked unpaid overtime hours under the FLSA	Robinson: he worked ~10-hour days five+ days/week (about 52 hrs/wk); testimony and notes suffice given employer’s failure to keep records	RHMD: Robinson’s evidence is unreliable, contradictory, and insufficient to meet the preponderance requirement	Court: Robinson failed to meet burden; credibility findings and inconsistencies permit affirmance
Whether the court improperly required Robinson to identify specific workweeks or produce particular documents	Robinson: district court effectively required proof of specific weeks and certain evidence, which was error	RHMD: plaintiff must prove uncompensated work by a preponderance; lack of specific recollection and missing corroboration undermine claim	Court: District court did not impose such a requirement; it permissibly noted missing evidence and lack of specific recollection when assessing plaintiff’s burden

Moran v. Al Basit LLC, 788 F.3d 201 (6th Cir.) (employee bears burden to prove uncompensated work under FLSA)
Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (U.S.) (employee must prove hours worked even where employer failed to keep records)
United States v. Aloi, 9 F.3d 438 (6th Cir.) (appellate deference to district court credibility findings)
Anderson v. City of Bessemer City, 470 U.S. 564 (U.S.) (appellate review of factfinding is limited when district court’s account is plausible)
Christian Legal Soc. Chapter of the Univ. of Cal. v. Martinez, 561 U.S. 661 (U.S.) (stipulations are binding and control the facts)