In the case of Peters v. Early Healthcare Giver, Inc., Muriel Peters, a certified nursing assistant, worked for Early Healthcare Giver, Inc. (EHCG) and consistently worked 119 hours in each two-week pay period, providing in-home care for an elderly patient. EHCG paid her a flat rate of $12 per hour, including hours worked beyond 40 hours per week.
After leaving the company, Peters sued EHCG for wrongfully withholding her overtime wages in the Circuit Court for Montgomery County. During the trial, EHCG’s president admitted to not paying Peters overtime, claiming that she was unaware that this was necessary. EHCG argued that federal law governed their payment of home healthcare workers who were under a federal program, exempting them from overtime pay under the “companionship services” exemption of the Fair Labor Standards Act (FLSA).
Despite the trial court denying Peters’s claim, noting that federal law preempted Maryland law and exempted EHCG from paying overtime, Peters appealed asserting unpaid overtime and treble damages.
The Court of Special Appeals found that the trial court erred in concluding that federal law preempted state wage laws. The Circuit Court then awarded Peters $6,201 in unpaid overtime wages (three times the owed amount) but denied enhanced damages.
Key lessons from this case:
- The case strengthens the position of employees seeking unpaid overtime as it shows that they can now claim up to three times the unpaid overtime under the WPCL, making these cases more appealing to plaintiffs’ lawyers.
- The case asserts that employers should ensure compliance with overtime laws or have a valid legal justification for not paying overtime due to the potential for treble damages and the possibility of recovering attorney’s fees.
- Employers must ensure they are either paying overtime at the appropriate rate for all hours worked beyond the regular schedule, while maintaining accurate records, or have a legitimate legal justification, supported by law, for not providing overtime pay.
If you want to know more about overtime regulations, read our guide on Maryland Overtime Laws.
