Bolos v. Waldorf=Astoria Management LLC

Bolos v. Waldorf-Astoria Management LLC

What Happened

A worker at the Grand Wailea resort challenged how the Waldorf-Astoria Management LLC calculated minimum wage pay. The dispute centered on whether employers could average wages across an entire week or had to ensure minimum wage was paid for each individual hour worked.

What the Court Decided

Hawaii's Supreme Court ruled that employers must pay at least minimum wage for every hour an employee works—not average it out over a week. This means an employer cannot claim they met minimum wage requirements by averaging hours together, even if the total came out to the right amount.

Why This Matters

This ruling protects Hawaiian workers from wage calculations that hide low-paying hours. For example, an employer cannot pay someone $5 per hour for some shifts if other shifts are higher, claiming it averages out correctly. Every single hour must meet Hawaii's minimum wage standard. This gives workers clearer protection and makes it harder for employers to use accounting tricks to pay less than required by law.