Rana v. Islam, No. 16-3966 (2d Cir. 2018)Annotate this Case
Because New York Labor Law does not call for awards of New York Labor Law (NYLL) liquidated damages on top of liquidated damages under the Fair Labor Standards Act (FLSA), district courts may not award cumulative liquidated damages for the same course of conduct under both statutes. Defendant Islam appealed the district court's damages orders after a default judgment was entered against defendants in an action filed by plaintiff, alleging violations of various state and federal labor and human trafficking laws. The Second Circuit vacated the damages award in this case under the FLSA in favor of the NYLL award.