“These are employees who could not provide their services of caring for clients in clients’ homes without at least some travel.”

💡 The court rejected Prestige’s claim that travel was separate from work, establishing that home healthcare inherently requires compensable travel.

“While the Department did not tell Prestige whether travel was compensable, it did inform Prestige that any time where its HHAs were providing services or were required to be available to provide services was time worked.”

💡 Prestige received explicit guidance about compensable time in 2017 but continued refusing to pay for travel, demonstrating willfulness.

“A violation is willful if the employer either knew or showed reckless disregard for the matter of whether its conduct was prohibited by the statute.”

💡 This legal standard allowed the court to extend the statute of limitations and award enhanced damages against Prestige.

“The PPA does not cover any time within that period, even if an employee does not engage in work throughout all of that period and has a rest period or a lunch period instead.”

💡 The Portal-to-Portal Act exemption does not apply to travel during the workday, only before and after, defeating Prestige’s primary legal defense.

“An HHA must always spend time traveling on a workday if he or she has multiple clients in different locations. Such travel is therefore integral and indispensable, and thus a compensable principal activity.”

💡 The court applied Supreme Court precedent to establish that necessary inter-client travel must be paid as part of the job.

“Rest periods of short duration, running from 5 minutes to about 20 minutes must be counted as hours worked.”

💡 Federal regulations clearly require payment for short breaks, yet Prestige systematically treated them as off-the-clock time.

“Prestige’s duty is simply to make a record so that the employer and employee have the most probative facts concerning the nature and amount of work performed.”

💡 By failing to track travel time, Prestige violated its legal obligation and made it nearly impossible for workers to prove hours worked.

“That Prestige’s notice came in the context of violating the FLSA’s overtime rules is also relevant.”

💡 The 2017 investigation provided clear notice that Prestige had already violated wage laws, making continued violations even more culpable.

“Because Prestige’s FLSA violations were willful, it lacked good faith; therefore, the District Court did not abuse its discretion in awarding backpay and liquidated damages.”

💡 Willful violators cannot claim they acted in good faith to reduce damages, ensuring Prestige faces full financial consequences.

“Work that is suffered or permitted is work time, no matter the employee’s reason for taking on more work. There is no genuine dispute that Prestige permits its employees to structure their workdays in a manner that necessitates travel.”

💡 Prestige cannot escape liability by claiming workers chose to travel; permitting the travel makes it compensable under federal law.

“Crandall’s testimony would erroneously tell the jury that the HHAs were entitled to a rate of pay that the law does not permit; that their overtime pay was based on that same unlawful rate of pay; and that the period for which they could be compensated was less than what the law required.”

💡 The court excluded Prestige’s expert for making fundamental errors about what federal law requires, eliminating a key defense.

“An employee has carried out his burden if he proves that he has in fact performed work for which he was improperly compensated and if he produces sufficient evidence to show the amount and extent of that work as a matter of just and reasonable inference.”

💡 When employers fail to keep proper records, workers can use reasonable estimates to prove damages, shifting the burden back to the employer.

“The Supreme Court has never contended that a damages calculation under Mount Clemens must be perfectly accurate, because, inevitably, these cases pit employees who might have access to work records against companies who should but do not.”

💡 Courts recognize that precise calculations are impossible when employers destroy or fail to create records, so reasonable approximations suffice.

“We exercise plenary review over the District Court’s grant of summary judgment. That means we review anew the District Court’s summary judgment decisions and apply the same standards that it was required to apply.”

💡 The Circuit Court independently reviewed all evidence and legal conclusions, providing a thorough second look that still found against Prestige.

“For all these reasons, we will affirm the District Court’s judgment.”

💡 After examining seven separate challenges raised by Prestige, the appellate court upheld every aspect of the ruling against the company.