No specific laws identified for this ruling.
On a certified question from the federal district court, the Hawaiʻi Supreme Court held that Hawaiʻi's minimum wage law (HRS §§ 387-2 and 387-12) requires a per-hour unit of measure, not the FLSA's per-workweek averaging approach, meaning employers must pay at least minimum wage for each hour worked.
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.
This summary was generated to explain the ruling in plain English and is not legal advice.
Court rulings like this one are useful, but every situation is different. Take 3 minutes to see which laws may protect you — it's free, private, and no account is required to start.
This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.
See something wrong, or named in this ruling and want it corrected or redacted? Request a correction.