Francisco Lagos Marmol v. Kalonymus Development Partners, LLC

Constitutional Issues

Does an obligation arising from a business transaction constitute a 'debt' under the Fair Debt Collection Practices Act?What is the scope of the FDCPA's protection regarding debts incurred for business purposes?

Rule Statements

"The FDCPA applies only to debts incurred for personal, family, or household purposes."

"A debt incurred for business purposes is not covered by the FDCPA."

Q: What is Francisco Lagos Marmol v. Kalonymus Development Partners, LLC about?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC is a case decided by Eleventh Circuit on December 2, 2025. It involves NEW.

Q: What court decided Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC was decided by the Eleventh Circuit, which is part of the federal judiciary. This is a federal appellate court.

Q: When was Francisco Lagos Marmol v. Kalonymus Development Partners, LLC decided?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC was decided on December 2, 2025.

Q: What is the citation for Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

The citation for Francisco Lagos Marmol v. Kalonymus Development Partners, LLC is . Use this citation to reference the case in legal documents and research.

Q: What type of case is Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC is classified as a "NEW" case. This describes the nature of the legal dispute at issue.

Q: What is the case name and what court decided it?

The case is Francisco Lagos Marmol v. Kalonymus Development Partners, LLC, and it was decided by the United States Court of Appeals for the Eleventh Circuit (ca11). This court reviews decisions from federal district courts within its jurisdiction.

Q: Who were the parties involved in this lawsuit?

The parties were Francisco Lagos Marmol, the plaintiff who brought the lawsuit, and Kalonymus Development Partners, LLC, the defendant company. Marmol was an employee seeking unpaid overtime wages, and Kalonymus was his employer.

Q: What was the main legal issue in Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

The central legal issue was whether Francisco Lagos Marmol's claims for unpaid overtime wages under the Fair Labor Standards Act (FLSA) were barred by the statute of limitations. Specifically, the court had to determine if Marmol filed his lawsuit within the applicable time frame.

Q: When was the lawsuit filed in relation to the alleged overtime violations?

The Eleventh Circuit affirmed the district court's decision, finding that Marmol's claims were time-barred. The court determined that Marmol filed his suit more than two years after he became aware of his right to overtime pay and his employer's alleged failure to pay it, thus exceeding the standard statute of limitations for non-willful FLSA violations.

Q: What is the Fair Labor Standards Act (FLSA) and what does it require?

The Fair Labor Standards Act (FLSA) is a federal law that establishes minimum wage, overtime pay, recordkeeping, and child labor standards affecting full-time and part-time workers in the private sector and in federal, state, and local governments. For non-exempt employees, it generally requires employers to pay overtime at a rate of one and a half times their regular rate of pay for all hours worked over 40 in a workweek.

Q: What was the nature of the dispute between Marmol and Kalonymus Development Partners?

The dispute centered on Francisco Lagos Marmol's claim that Kalonymus Development Partners, LLC, failed to pay him overtime wages as required by the FLSA. Marmol alleged he worked hours that should have qualified for overtime pay, but the company did not compensate him accordingly.

Q: Is Francisco Lagos Marmol v. Kalonymus Development Partners, LLC published?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What topics does Francisco Lagos Marmol v. Kalonymus Development Partners, LLC cover?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC covers the following legal topics: Fair Labor Standards Act (FLSA) overtime claims, Statute of limitations for FLSA violations, Willful vs. non-willful violations under FLSA, Employee awareness of overtime policies, Summary judgment standard.

Q: What was the ruling in Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

The court ruled in favor of the defendant in Francisco Lagos Marmol v. Kalonymus Development Partners, LLC. Key holdings: The Eleventh Circuit affirmed the district court's decision, holding that Francisco Lagos Marmol's Fair Labor Standards Act (FLSA) claim for unpaid overtime was barred by the statute of limitations.; The court found that Marmol's own testimony demonstrated he was aware of his entitlement to overtime pay and the employer's alleged failure to pay it more than two years prior to filing suit, thus activating the two-year statute of limitations for non-willful violations.; The court rejected Marmol's argument for tolling the statute of limitations based on his limited English proficiency and lack of legal knowledge, as he failed to present evidence that the employer actively misled him or prevented him from seeking information about his rights.; The court concluded that ignorance of the law, without more, is insufficient to toll the statute of limitations under the FLSA.; The court determined that Marmol did not present sufficient evidence to establish a "willful" violation, which would have extended the statute of limitations to three years..

Q: Why is Francisco Lagos Marmol v. Kalonymus Development Partners, LLC important?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC has an impact score of 15/100, indicating narrow legal impact. This decision reinforces that plaintiffs bear the burden of demonstrating timely filing or grounds for tolling in FLSA cases. It clarifies that general lack of legal knowledge or language barriers, without evidence of employer deception or obstruction, will not overcome the statute of limitations, emphasizing the importance of proactive inquiry into one's rights.

Q: What precedent does Francisco Lagos Marmol v. Kalonymus Development Partners, LLC set?

Francisco Lagos Marmol v. Kalonymus Development Partners, LLC established the following key holdings: (1) The Eleventh Circuit affirmed the district court's decision, holding that Francisco Lagos Marmol's Fair Labor Standards Act (FLSA) claim for unpaid overtime was barred by the statute of limitations. (2) The court found that Marmol's own testimony demonstrated he was aware of his entitlement to overtime pay and the employer's alleged failure to pay it more than two years prior to filing suit, thus activating the two-year statute of limitations for non-willful violations. (3) The court rejected Marmol's argument for tolling the statute of limitations based on his limited English proficiency and lack of legal knowledge, as he failed to present evidence that the employer actively misled him or prevented him from seeking information about his rights. (4) The court concluded that ignorance of the law, without more, is insufficient to toll the statute of limitations under the FLSA. (5) The court determined that Marmol did not present sufficient evidence to establish a "willful" violation, which would have extended the statute of limitations to three years.

Q: What are the key holdings in Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

1. The Eleventh Circuit affirmed the district court's decision, holding that Francisco Lagos Marmol's Fair Labor Standards Act (FLSA) claim for unpaid overtime was barred by the statute of limitations. 2. The court found that Marmol's own testimony demonstrated he was aware of his entitlement to overtime pay and the employer's alleged failure to pay it more than two years prior to filing suit, thus activating the two-year statute of limitations for non-willful violations. 3. The court rejected Marmol's argument for tolling the statute of limitations based on his limited English proficiency and lack of legal knowledge, as he failed to present evidence that the employer actively misled him or prevented him from seeking information about his rights. 4. The court concluded that ignorance of the law, without more, is insufficient to toll the statute of limitations under the FLSA. 5. The court determined that Marmol did not present sufficient evidence to establish a "willful" violation, which would have extended the statute of limitations to three years.

Q: What cases are related to Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

Precedent cases cited or related to Francisco Lagos Marmol v. Kalonymus Development Partners, LLC: 29 U.S.C. § 255(a); 29 U.S.C. § 207; 29 U.S.C. § 216(b).

Q: What was the holding of the Eleventh Circuit in this case?

The Eleventh Circuit affirmed the district court's grant of summary judgment to Kalonymus Development Partners, LLC. The appellate court held that Marmol's FLSA claims for unpaid overtime were time-barred because he filed his lawsuit more than two years after he knew about his right to overtime and the employer's alleged non-payment.

Q: What is the statute of limitations for FLSA claims, and how does it apply here?

The standard statute of limitations for FLSA claims is two years, unless the violation is willful, in which case it is three years. The court found that Marmol's own testimony indicated he was aware of his right to overtime and the employer's failure to pay it more than two years before filing suit, triggering the two-year limit for non-willful violations.

Q: What legal standard did the court apply to determine if the claims were time-barred?

The court applied the standard for summary judgment, which requires determining if there is a genuine dispute of material fact and if the moving party is entitled to judgment as a matter of law. In this instance, the court examined Marmol's testimony to ascertain when he became aware of his FLSA rights and the alleged violation to apply the statute of limitations.

Q: Did the court consider Marmol's limited English proficiency and lack of legal knowledge?

Yes, the court considered Marmol's arguments that his limited English proficiency and lack of legal knowledge should toll (pause) the statute of limitations. However, the court rejected this argument because Marmol presented no evidence that Kalonymus actively misled him or prevented him from inquiring about his rights, which is typically required for tolling based on such factors.

Q: What kind of evidence did the court rely on to determine when Marmol knew about his rights?

The court primarily relied on Francisco Lagos Marmol's own deposition testimony. His testimony established that he was aware of his entitlement to overtime pay and that Kalonymus Development Partners was not paying it, which was crucial for determining the start date of the statute of limitations.

Q: What does it mean for a violation to be 'willful' under the FLSA statute of limitations?

A willful violation under the FLSA means the employer knew or showed reckless disregard for whether its conduct was prohibited by the FLSA. If a violation is deemed willful, the statute of limitations extends to three years instead of the usual two. The court found no evidence to suggest Kalonymus's actions were willful in this case.

Q: What is the significance of 'summary judgment' in this case?

Summary judgment is a procedural device where a court can decide a case without a full trial if there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. The district court granted summary judgment to Kalonymus, and the Eleventh Circuit affirmed this decision, meaning the case was resolved based on the legal question of the statute of limitations without a trial.

Q: What is the burden of proof regarding the statute of limitations in an FLSA case?

Generally, the employer bears the burden of proving that the statute of limitations bars the employee's claim. Kalonymus Development Partners had to demonstrate that Marmol's claims were filed outside the applicable two-year period and that Marmol was aware of his rights and the violation within that period.

Q: How does Francisco Lagos Marmol v. Kalonymus Development Partners, LLC affect me?

This decision reinforces that plaintiffs bear the burden of demonstrating timely filing or grounds for tolling in FLSA cases. It clarifies that general lack of legal knowledge or language barriers, without evidence of employer deception or obstruction, will not overcome the statute of limitations, emphasizing the importance of proactive inquiry into one's rights. As a decision from a federal appellate court, its reach is national. This case is moderate in legal complexity to understand.

Q: How does this ruling impact other employees in similar situations?

This ruling emphasizes the importance for employees to be aware of their rights under the FLSA and to act promptly if they believe their employer is violating these rights. Employees who delay filing claims, even with limited English proficiency or legal knowledge, risk having their claims time-barred if they cannot show active deception by the employer.

Q: What should employers do to ensure compliance with FLSA overtime rules after this case?

Employers should ensure clear communication with all employees regarding wage and hour policies, including overtime entitlements. They should maintain accurate records and be prepared to demonstrate that employees were informed of their rights and that pay practices comply with the FLSA to avoid potential statute of limitations defenses being invalidated.

Q: What are the practical implications for employees who are not fluent in English?

The ruling suggests that employees with limited English proficiency must take proactive steps to understand their employment rights, including overtime pay. While the court acknowledged the potential barrier, it requires evidence of active misleading by the employer to toll the statute of limitations, placing a burden on the employee to seek clarification.

Q: How might this case affect future FLSA litigation strategy?

This decision may encourage employers to more aggressively assert statute of limitations defenses, particularly in cases involving employees with potential language or knowledge barriers. Plaintiffs' attorneys may need to focus on gathering stronger evidence of employer deception or willfulness to overcome these defenses.

Q: What is the real-world consequence for Francisco Lagos Marmol?

The real-world consequence for Francisco Lagos Marmol is that he is barred from recovering any unpaid overtime wages he may have been owed by Kalonymus Development Partners, LLC, for the period preceding the lawsuit that fell outside the two-year statute of limitations. His claims were dismissed based on the timing of his filing.

Q: Does this case set a new precedent for FLSA statute of limitations?

This case applies existing precedent regarding the FLSA statute of limitations and the conditions for tolling. It reinforces the principle that an employee's subjective awareness of their rights and the employer's non-compliance triggers the statute, and that objective evidence of employer misconduct is generally needed to extend that period.

Q: How does this ruling compare to other FLSA statute of limitations cases?

The ruling aligns with many other FLSA cases where courts have strictly applied the statute of limitations when employees have knowledge of their rights and the employer's alleged violations. It highlights the common judicial stance that ignorance of the law or language barriers alone are insufficient to toll the statute without proof of employer deception.

Q: What legal doctrines govern the application of statutes of limitations in employment law?

The application of statutes of limitations in employment law is governed by principles of timeliness and repose, ensuring that claims are brought within a reasonable period. Doctrines like equitable tolling and equitable estoppel can sometimes extend these periods, but they typically require specific actions or omissions by the defendant that actively prevent the plaintiff from filing suit.

Q: What was the docket number in Francisco Lagos Marmol v. Kalonymus Development Partners, LLC?

The docket number for Francisco Lagos Marmol v. Kalonymus Development Partners, LLC is 23-13678. This identifier is used to track the case through the court system.

Q: Can Francisco Lagos Marmol v. Kalonymus Development Partners, LLC be appealed?

Potentially — decisions from federal appellate courts can be appealed to the Supreme Court of the United States via a petition for certiorari, though the Court accepts very few cases.

Q: How did this case reach the Eleventh Circuit Court of Appeals?

The case reached the Eleventh Circuit on appeal after the U.S. District Court for the Southern District of Florida granted summary judgment in favor of Kalonymus Development Partners, LLC. Francisco Lagos Marmol appealed this decision to the Eleventh Circuit, seeking to overturn the dismissal of his FLSA claims.

Q: What is the role of the district court in this case?

The U.S. District Court for the Southern District of Florida initially heard the case. It was responsible for ruling on pre-trial motions, including the defendant's motion for summary judgment. The district court granted this motion, concluding that Marmol's claims were time-barred, which then led to the appeal.

Q: What does it mean that the Eleventh Circuit 'affirmed' the district court's decision?

Affirming the district court's decision means that the Eleventh Circuit agreed with the lower court's ruling. The appellate court found no errors in the district court's application of the law or its factual findings based on the evidence presented, and therefore upheld the dismissal of Marmol's FLSA claims as time-barred.