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United States Fourth Circuit

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Cruz v. Maypa, 13-2363

In this case, plaintiff alleges that she was forced tow work for the defendants for wages well below the minimum from 2002 until her escape in 2008. The district court dismissed all of her claims, brought under the Victims of Trafficking and Violence Protection Act (TVPA), the Fair Labor Standards Act (FLSA), and Virginia state contract law, as time-barred. The dismissal of plaintiff's state law claims is affirmed, and the dismissal of plaintiff's TVPA and FLSA claims are reversed and remanded, where: 1) the TVPA claims may be timely under the ten-year limitations period if they were tolled until within four years of the TVPRA's enactment; and 2) the FLSA claim may be timely if plaintiff received actual notice of her rights within three years of filing this suit.

Appellate Information

  • Decided 12/01/2014
  • Published 12/01/2014


  • Gregory


  • United States Fourth Circuit


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