Ubnare v. Trillian Technologies, Inc.

Summary

The United States District Court for the District of Columbia grants in part the plaintiff’s motion for default judgment in an action alleging violations of the District of Columbia Wage Payment and Collection Law and breach of contract. The court awards unpaid wages, unpaid PTO, wire transfer fees, a laptop charger expense, and liquidated damages, while deferring rulings on attorney’s fees, costs, and prejudgment interest pending supplemental briefing.

Holdings

1. The court had subject-matter jurisdiction under 28 U.S.C. § 1332 because the parties were completely diverse and the amount in controversy exceeded $75,000, and it had personal jurisdiction over Defendant because Defendant was an employer that resided and transacted business in the District of Columbia.
2. Plaintiff established Defendant's liability under the District of Columbia Wage Payment and Collection Law by alleging and supporting that Defendant failed to pay wages earned on the designated regular paydays.
3. Plaintiff was entitled to $22,762.68 for unpaid wages, unpaid PTO, wire-transfer fees, and reimbursement for the work-expensed laptop charger.
4. The DCWPCL required an award of treble damages, and Plaintiff was entitled to $67,745.37 in liquidated damages based on unpaid wages and unpaid PTO.
5. The court deferred ruling on attorney's fees and costs because Plaintiff did not provide sufficiently detailed information identifying which attorney performed each task or describing the specific work performed.
6. Post-judgment interest was proper under 28 U.S.C. § 1961, but the court deferred ruling on prejudgment interest because Plaintiff had not provided supporting authority or addressed the applicable rate.

Questions Presented

1. Whether the court had subject-matter and personal jurisdiction to enter a default judgment.
2. Whether Plaintiff's well-pleaded allegations and supporting evidence established Defendant's liability under the District of Columbia Wage Payment and Collection Law.
3. Whether Plaintiff adequately proved the amounts of unpaid wages, unpaid PTO, wire-transfer fees, and work-expense reimbursement.
4. Whether Plaintiff was entitled to mandatory treble liquidated damages under the DCWPCL.
5. Whether Plaintiff sufficiently supported his requests for attorney's fees and costs.
6. Whether Plaintiff established entitlement to prejudgment and post-judgment interest.

Disposition

other