SIGNIFICANT CASE SUMMARY
Washington, DC Case Summary
Shea Yeleen Health And Beauty LLC v. Office of Wage-Hour
District of Columbia Court of Appeals
No. 24-AA-0526
Decided: September 4, 2025
The D.C. Wage Payment and Collection Law allows a claimant to seek damages and a statutory penalty even when there is a good faith dispute regarding unpaid wages.
Background
Petitioner is a small business that imports shea butter from Ghana and sells beauty products produced from it. Respondent was hired by Petitioner to perform social media marketing for Petitioner. After her departure from the petitioner-company, Respondent contended that she was owed a timely payment of unpaid wages pursuant to the D.C. Wage Payment and Collection Law (“WPCL”), codified at D.C. Code §§ 32-1301 et seq.
Respondent brought her claim before the Office of Administrative Hearings (“OAH”). OAH ordered Petitioner to pay her unpaid wages. Petitioner appealed this Order to the D.C. Court of Appeals, which concluded that Respondent worked in a dual-capacity, as an independent contractor and employee. The Court of Appeals in that case held that the WPCL applies only to wages earned as an employee and remanded the case to the OAH to determine the hours that Respondent worked as an employee and to adjust her award accordingly. The OAH then determined that Respondent worked 600 hours as an employee and ordered Petitioner to pay unpaid wages. The OAH also imposed a statutory penalty on Respondent for violating the WPCL. Petitioner then brought the instant appeal arguing that, among other things, the OAH had applied the wrong burden-shifting framework such that it had incorrectly calculated the penalty assessed for unpaid wages.
Holding
The Court of Appeals affirmed the OAH order in its entirety. The Court of Appeals clarified that the WPCL was amended to allow an employee to pursue disputed wages under the act although the employer has paid the amount of unpaid wages “which he concedes to be due.” The Court of Appeals also held that Petitioner bore the burden of proof regarding Respondent’s amount of hours worked as an employee. The burden shifted to Petitioner due to Petitioner’s failure to maintain precise records of Respondent’s hours. The Court held that Respondent presented reasonable evidence regarding her hours as an employee, as opposed to an independent contractor. Thus, on remand, OAH apportioned reasonable percentage of these hours to count towards Respondent’s employee hours. The burden then shifted to Petitioner to provide evidence negating this apportionment. Petitioner did not do so. Finally, the Court of Appeals held that the burden of proof regarding compensation already provided to Respondent had also shifted to Petitioner. The Respondent bore the initial burden of proof regarding compensation received and, once shown, the burden shifted under the code if the Petitioner failed to keep records of compensation as required by law. As Petitioner failed to keep such records, Respondent provided reasonable evidence of compensation already provided.
Questions about this case can be directed to Joanne Lee at (202) 945-9504 or jlee@tthlaw.com.