Sanchez v. El Barrio's Car Service, Inc

Background

Oscar Sanchez brought the action individually and on behalf of others similarly situated against El Barrio’s Car Service, Inc., New Easy Way Radio Dispatch, Inc., Germania Altamirano, and Jose Altamirano. He sought unpaid wages under the Fair Labor Standards Act and the New York Labor Law.

On October 3, 2022, the court entered a default judgment against the defendants. A default judgment is a judgment entered after a party fails to defend the case. The court referred the issue of damages to Magistrate Judge Stewart D. Aaron for an inquest, meaning a proceeding to determine the amount owed.

Report and Recommendation

Magistrate Judge Aaron recommended awarding Sanchez $107,851.90 for unpaid wages, unpaid overtime compensation, and spread-of-hours pay. He also recommended an equal amount—$107,851.90—in liquidated damages, plus prejudgment interest. The recommendation stated that interest should be calculated at the statutory rate on $107,851.90 beginning May 6, 2016. No party filed objections.

Ruling

Because there were no objections, Judge Daniels reviewed the report for clear error. He found no error, clear or otherwise, in Magistrate Judge Aaron’s analysis and adopted the recommended judgment in full.

The court ordered final judgment requiring the defendants to pay: (1) $107,851.90 for unpaid wages, unpaid overtime compensation, and spread-of-hours pay; (2) $107,851.90 in liquidated damages; and (3) prejudgment interest at the statutory rate on $107,851.90, calculated beginning May 6, 2016. The Clerk of Court was directed to enter judgment and close the action.