Savings Bank v. O'Neil

In Savings Bank v. O'Neil, 324 U.S. 697, 65 S. Ct. 895, 89 L. Ed. 1296 (1945), the Court considered whether an employee covered by the FLSA could waive or release his right to liquidated damages under the penalty provisions of Section 16(b) of the Act, 29 U.S.C. 216(b). In examining the mandatory nature of liquidated damages under the FLSA, the Court noted that the Act constitutes a Congressional recognition that failure to pay the statutory minimum on time may be so detrimental to maintenance of the minimum standard of living "necessary for health, efficiency, and general well-being of workers" and to the free flow of commerce, that double payment must be made in the event of delay in order to insure restoration of the worker to that minimum standard of well-being. Id. at 707.