## Facts

- Humberto Reyes worked for Aqua Life Corporation and alleged he regularly worked more than forty hours per week without receiving overtime pay.
- Reyes sued for unpaid overtime wages under the Fair Labor Standards Act (FLSA).
- At trial, Aqua Life’s vice president testified he believed an overtime exemption applied, but also admitted that before the lawsuit he was unaware of the FLSA’s existence.
- A jury found Aqua Life liable for unpaid overtime and awarded Reyes $14,770 in back wages.
- The district court denied Reyes liquidated damages despite the jury’s liability finding.
- During remand proceedings after an earlier appeal, Aqua Life stipulated that Reyes met his burden to extend the FLSA statute of limitations, resolving any time-bar dispute.
- Reyes appealed the renewed denial of liquidated damages after post-verdict proceedings following a second trial.

## Issues

1. Whether the district court erred by denying FLSA liquidated damages after a jury found an overtime violation and awarded unpaid wages.
2. Whether Aqua Life proved both subjective good faith and objectively reasonable grounds for believing its pay practices complied with the FLSA, sufficient to avoid liquidated damages.
3. Whether the district court’s handling of post-verdict matters (including defenses asserted during the litigation) affected the liquidated-damages determination.

## Decision

- The Eleventh Circuit reversed the denial of liquidated damages and remanded.
- The court held Aqua Life did not carry its burden to establish the FLSA’s good-faith defense to liquidated damages.
- The court concluded the record—particularly management’s claimed exemption “research” paired with admitted pre-suit ignorance of the FLSA—could not support withholding liquidated damages.

## Legal Principles

- Under the FLSA, liquidated damages equal to unpaid overtime are the default remedy once a violation is found.
- A court may reduce or deny liquidated damages only if the employer proves both (1) subjective good faith and (2) objectively reasonable grounds for believing its conduct was lawful.
- The employer bears a substantial burden; after-the-fact litigation positions and unsupported assertions of exemption reliance do not, without more, establish good faith or reasonable grounds.

## Conclusion

The Eleventh Circuit required an award of FLSA liquidated damages because Aqua Life failed to prove it acted in good faith or had objectively reasonable grounds for its overtime practices, making the district court’s denial of liquidated damages reversible error.


Reyes v. Aqua Life Corp., 632 F. App’x 552 (11th Cir. 2015)