Doty v. Elias

Becky Doty and other restaurant employees (plaintiffs) worked for Eddy Elias (defendant), who paid no hourly wage but let them keep all tips. The employees sued, claiming this violated federal labor law. Before trial, each employee wrote out from memory a schedule of the days and hours she had worked. At trial, the judge let the employees look at these schedules while testifying, though the schedules themselves were never admitted into evidence. The district court found Elias liable. Elias appealed, arguing that letting the employees use the schedules amounted to admitting inadmissible hearsay.