Caro-Galvan v. Curtis Richardson, Inc.
United States Court of Appeals for the Eleventh Circuit
993 F.2d 1500 (1993)
Curtis Richardson, Inc. (Richardson) (defendant) owned and operated a farm, employing migrant workers (workers) (plaintiffs) to harvest crops, which were principally ferns, and to perform other field work. Richardson paid the workers on a piece-rate basis for the ferns they harvested. For general field work, Richardson paid minimum wage. While employed by Richardson, the workers lived in trailers for which Richardson charged $150 per month, regardless of the number of occupants. Richardson deducted rent and utility costs from the workers’ paychecks, which often caused the workers’ take-home pay to fall below minimum wage. The workers sued Richardson under the Fair Labor Standards Act (FLSA), alleging that Richardson violated the FLSA’s minimum-wage requirements because the deductions brought their net pay below minimum wage. Richardson introduced conclusory testimony that the rent deductions were reasonable. The district court found that the workers had not proved that the deductions were unreasonable and dismissed the complaint under Fed. R. Civ. P. 41(b) at the close of the workers’ case-in-chief. The workers appealed.
Rule of Law
Holding and Reasoning (Kravitch, J.)
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