Sivaraman v. Guizzetti & Associates Ltd, 228 A.3d 1066

Background

Sivaraman was hired as a manager by Guizzetti & Associates (G&A); Guizzetti promised $40,000/year salary, a $2,000 relocation stipend, and reimbursement for business expenses.
G&A failed to pay May 2014 salary and one December 2015 paycheck; it also never paid the $2,000 stipend or $2,044.28 in expense reimbursements.
After Sivaraman demanded payment in June 2016, G&A terminated him; Guizzetti then asked him to continue as an unpaid consultant from July 1–Oct. 7, 2016.
The trial court entered defaults against G&A and Guizzetti, held a damages hearing, and awarded $20,084.21 (including some wages, stipend, expenses, consultancy pay at minimum wage, and treble for consultancy wages), but declined to treble the unpaid salary or stipend and awarded no damages for retaliation.
On appeal Sivaraman challenged: (1) refusal to treble unpaid wages; (2) exclusion of stipend and expenses from the definition of "wages"; (3) denial of damages for retaliation despite default; and (4) the court’s discounting of hours claimed for the consultancy period.
The D.C. Court of Appeals vacated and remanded: it held treble damages are mandatory for unpaid wages, the relocation stipend is a wage but expense reimbursements are not, and the retaliation award must be reconsidered; it affirmed the court’s factfinding about consultancy hours.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether treble damages under the WPCL are mandatory for unpaid wages	Sivaraman: treble damages are mandatory for all unpaid wages he requests	Trial court/defendants: court treated trebling as discretionary and declined to treble some items	Treble is mandatory under §32‑1308 and Klingaman; trial court erred; remand to apply treble to unlawfully withheld wages (salary and stipend)
Whether the relocation stipend and expense reimbursements qualify as "wages" under the WPCL	Sivaraman: both the $2,000 relocation stipend and $2,044.28 expenses are wages	Trial court/defendants: neither stipend nor reimbursements are wages (wages = pay for work/services)	Moving stipend is a wage (bonus/fringe/other remuneration); expense reimbursements are not wages (they merely make the employee whole)
Whether the trial court abused its discretion by awarding no damages on the retaliation claim after default	Sivaraman: default precluded relitigating liability; court must treat claim as admitted and fix damages	Trial court: expressed doubts about merits and declined to award back pay	Court abused discretion to the extent it reassessed merits after default; remand to reassess damages for retaliation and, if none awarded, to explain reasons without reopening liability
Whether the trial court improperly discounted Sivaraman’s claimed consultancy hours	Sivaraman: calendar showed consistent 66 hrs/wk and many overtime hours	Guizzetti: Sivaraman did no post-termination work; company was closed	Court did not err; judge could discredit calendar as implausible and choose a reasonable intermediate finding (40 hrs/wk for 6 weeks); factfinding affirmed

Key Cases Cited

Klingaman v. Holiday Tours, Inc., 309 A.2d 54 (D.C. 1973) (liquidated/treble damages under predecessor statute are mandatory)
Parrish v. District of Columbia, 718 A.2d 133 (D.C. 1998) (interpretation of statutory "shall" as mandatory)
Riggs Nat'l Bank v. District of Columbia, 581 A.2d 1229 (D.C. 1990) (statutory "shall" creates duty, not option)
Eaglin v. District of Columbia, 123 A.3d 953 (D.C. 2015) (de novo review for statutory interpretation)
Lockhart v. Cade, 728 A.2d 65 (D.C. 1999) (after default, court should be confined to proof of damages only)
Kakaes v. George Washington Univ., 790 A.2d 581 (D.C. 2002) (trial judge as factfinder may credit or disregard damage calculations)
Central Ill. Pub. Serv. Co. v. United States, 435 U.S. 21 (U.S. 1978) (discussion of "wages" as narrower than income)
Rowan Cos. v. United States, 452 U.S. 247 (U.S. 1981) ("wages" distinguished from broader concepts like income)