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Nelson v. Alabama Institute for Deaf and Blind

N.D. Ala.June 6, 1995No. 1:93-cv-02143Cited 12 times
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Case Details

Judge(s)
Acker
Nature of Suit — the legal category of the dispute
710 Fair Labor Standards Act
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
motion to dismiss
State
Alabama

Related Laws

No specific laws identified for this ruling.

Claim Types

Wage Theft

Outcome

The court granted plaintiffs' motion to alter judgment, holding that houseparents should have been compensated for sleep time under the Fair Labor Standards Act and that the employer's good faith defense under 29 U.S.C. § 259 was not available because the employer's policy did not conform to the relevant written DOL interpretation.

What This Ruling Means

**What Happened** Workers at the Alabama Institute for Deaf and Blind worked as "houseparents," living on campus and caring for students around the clock. The institute didn't pay these employees for the time they spent sleeping overnight while on duty. The houseparents sued, claiming they should be paid for all hours they were required to stay at the facility, including sleep time. **What the Court Decided** The court ruled in favor of the workers. It found that houseparents must be paid for their sleep time under the Fair Labor Standards Act because they were required to stay on the premises and respond to student needs throughout the night. The court also rejected the institute's defense that it acted in "good faith" based on its understanding of wage laws, since the employer's pay policy didn't follow official Department of Labor guidelines. **Why This Matters for Workers** This case shows that employees who must sleep at their workplace while remaining "on call" are generally entitled to pay for that time. Workers in similar positions—like overnight caregivers, security guards, or residential facility staff—may have strong claims for unpaid wages if their employers aren't compensating them for required sleep time.

This summary was generated to explain the ruling in plain English and is not legal advice.

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