Li v. Chinatown Take-Out, Inc.

Summary

Second Circuit affirmed bench trial award for FLSA and NYLL wage-and-hour claims, holding that district court's credibility determinations regarding compensable hours, meal periods, and straight-time wages were not clearly erroneous. The court upheld damages calculation using a 40-hour divisor for overtime rate and capped statutory damages for wage notice violations at the pre-2015 amendment maximum of $2,500. Denial of Rule 60(b)(3) motion based on alleged perjury was affirmed because defendants were not prevented from fully presenting their case.

Holdings

1. The district court's credibility determinations were not clearly erroneous because the court was entitled to credit Defendants' testimony over Plaintiffs' recollection.
2. The district court's calculation of damages was not clearly erroneous; the court properly applied the law.
3. The district court did not abuse its discretion because Defendants were not prevented from presenting their case.

Questions Presented

1. Whether the district court clearly erred in its credibility determinations regarding Plaintiffs' compensable hours.
2. Whether the district court erred in calculating damages, including straight time, overtime, and statutory damages for wage notice violations.
3. Whether the district court abused its discretion in denying Defendants' Rule 60(b)(3) motion.

Disposition

affirmed