In the case of Medina v. Kevorkian Cleaning Company, Inc., Wendy Medina filed a lawsuit in 2018 claiming that Kevorkian Cleaning Company (Kevorkian) failed to pay her the minimum wage and also denied her overtime pay. Medina worked for Kevorkian intermittently as a cleaner at various restaurants in 2015 and rejoined in 2016.
Medina’s lawsuit against Kevorkian asserted three counts under the FLSA, D.C. Minimum Wage Revision Act (DCMWRA), and D.C. Wage Payment and Collection Law. Kevorkian sought summary judgment arguing that Medina’s claims should be rejected because it was outside of the statute of limitations or because she was an independent contractor, not an employee. Additionally, Kevorkian argued that they paid Medina at least the minimum wage, and she exaggerated the number of hours she had worked.
Medina attempted to salvage her DCMWRA claim by pointing to an exception in the law that states the statute of limitations does not begin until the employer posts or provides the required notice. She argued that the defendants failed to comply with the notice and posting requirements, thus tolling the limitations period. However, the parties offered conflicting evidence regarding whether the defendants satisfied these requirements.
The court found that there were disputes over facts that affected the outcome of the case. Ultimately, the court denied most of the motions from both Medina’s and Kevorkian’s sides. However, it ruled in favor of Kevorkian on part of Medina’s FLSA claims because it was considered barred by the statute of limitations.
Key lessons from this case:
- Statutes of limitations apply to wage and overtime claims, and timely filing is essential for an employee to claim what they are owed.
- Employers may be required to post notices related to wage and hour laws in conspicuous locations at the workplace. Failure to comply with these notice requirements could potentially affect the running of the statute of limitations.
- The court cannot weigh conflicting evidence or make credibility determinations for a summary judgment. Each party has the responsibility to support their claims with relevant materials.
If you want to know more about overtime regulations, read our guide on District of Columbia Overtime Laws.
