Rana v. Islam
887 F.3d 118 (2d Cir. 2018)
United States Court of Appeals, Second Circuit · April 6, 2018
What the court decided
A worker cannot recover liquidated damages twice over for the same unpaid wages under both the federal Fair Labor Standards Act and the New York Labor Law. The wording of the two liquidated damages provisions is not identical, but there are "no meaningful differences, and both are designed to deter wage-and-hour violations in a manner calculated to compensate the party harmed."
Who won
Mixed, and a partial win for the employer: the worker kept his judgment but the duplicative liquidated damages award was vacated.
Why it matters for salespeople
This is the case that ties the New York standard to the federal one. It is why the federal decisions on good faith are read as governing a New York Labor Law claim.
Key passage: 887 F.3d 118 (2d Cir. 2018) at 123.
Read the decision (PDF) Marked with official reporter pages for citation.
Source of the text: govinfo.gov (official slip opinion, United States Courts collection) — https://www.govinfo.gov/content/pkg/USCOURTS-ca2-16-03966/pdf/USCOURTS-ca2-16-03966-0.pdf. This page summarizes the decision in plain language; the court’s own words are in the PDF above.