## Facts

- Indigent farmworkers worked for a Florida fern grower from 1983–1989, performing harvesting and other field tasks.
- Work and production were seasonal: harvesting was heaviest from January through May, with lower production in off-peak months.
- Workers were paid largely by piece rate; during peak periods earnings often exceeded minimum wage, but during slower periods earnings allegedly fell below minimum wage unless supplemented.
- The workers alleged the employer failed to pay minimum wage for all hours in certain workweeks and failed to keep or provide accurate wage-and-hour records and wage statements.
- Workers testified that the employer’s documentation and recording practices prevented them from determining their hours, piece-rate units, rates, or whether minimum wage was met on a weekly basis.
- After the workers presented their evidence at a bench trial, the employer moved for involuntary dismissal under Federal Rule of Civil Procedure 41(b).
- The district court granted the Rule 41(b) motion and dismissed the claims under the Fair Labor Standards Act (FLSA) and the Migrant and Seasonal Agricultural Worker Protection Act (AWPA).

## Issues

1. Whether involuntary dismissal at the close of plaintiffs’ evidence was proper where plaintiffs presented testimony and evidence supporting reasonable inferences of FLSA minimum-wage and recordkeeping violations.
2. Whether, given allegedly inadequate employer records, plaintiffs’ evidence was sufficient under the FLSA burden-shifting rule to require the employer to produce precise records or negate plaintiffs’ reasonable inferences.
3. Whether plaintiffs’ testimony and evidence were sufficient to establish prima facie AWPA violations concerning required disclosures, wage statements, and recordkeeping.

## Decision

- The Eleventh Circuit reversed the involuntary dismissal and remanded for further proceedings.
- The court held plaintiffs’ evidence was sufficient to proceed on FLSA claims under the relaxed proof standard applicable when employer records are inadequate.
- The court held plaintiffs’ evidence was sufficient to proceed on AWPA claims regarding missing or inadequate disclosures, wage statements, and required records.
- The court concluded the district court applied an overly demanding evidentiary standard by effectively requiring workers to prove exact hours and wages despite statutory recordkeeping duties placed on employers.

## Legal Principles

- Rule 41(b) involuntary dismissal is improper when plaintiffs’ evidence, evaluated under the governing statutory burdens, shows a right to relief or presents factual disputes for resolution.
- Under the FLSA, when an employer’s records are inadequate, an employee meets the prima facie burden by producing evidence permitting a “just and reasonable inference” of hours worked and uncompensated wages; the burden then shifts to the employer to produce precise evidence or rebut the inference.
- FLSA minimum-wage compliance is assessed on a workweek-by-workweek basis; high earnings in some weeks do not cure shortfalls in other weeks.
- AWPA requires agricultural employers to provide written employment term disclosures, accurate wage statements, and records reflecting the basis of pay, piecework units, hours worked, and total earnings; worker testimony can establish prima facie noncompliance when records and statements are missing or insufficient.

## Conclusion

The Eleventh Circuit held that farmworkers’ testimony and supporting evidence, combined with allegedly deficient employer records, established prima facie FLSA and AWPA claims and required the case to proceed beyond the close of plaintiffs’ evidence, reversing the Rule 41(b) dismissal and remanding for further proceedings.


Caro-Galvan v. Curtis Richardson, Inc., 993 F.2d 1500 (11th Cir. 1993)