Blanco v. Samuel, No. 22-13669 (11th Cir. 2024)Annotate this Case
Maria Blanco, the plaintiff, worked as a nanny and housekeeper for Anand Samuel and Dr. Lindsey Finch (the defendants), for three years, working for 79 hours each week. Blanco filed a lawsuit to collect overtime wages for 39 hours of the 79 hours she worked each week. The defendants disputed Blanco’s claim for overtime pay, arguing that she fell under a provision of the Fair Labor Standards Act (FLSA) that exempts “any employee who is employed in domestic service in a household and who resides in such household” from receiving overtime compensation. The district court agreed with the defendants, ruling that Blanco “resided” in their house, and hence was exempted from overtime compensation.
The United States Court of Appeals for the Eleventh Circuit, however, disagreed with the lower court's decision. The court of appeals concluded that Blanco did not “reside” in the defendants’ house, as she maintained a separate residence and left the defendants’ house after each of her shifts. Therefore, Blanco was not exempted from overtime pay under the FLSA. The court of appeals also concluded that there was a genuine dispute of material fact as to whether the defendants were Blanco’s employer, which the lower court needed to resolve on remand. Thus, the court of appeals vacated the district court’s decision in part and remanded the case for further proceedings.