Melendez v. Rockaway Maintenance Partners, Corp.

Background

David Melendez’s amended complaint alleged that the defendants, for whom he worked as a superintendent from April 2017 through February 2021, failed to pay required minimum and overtime wages. He also alleged violations involving wage notices and accurate pay statements under the Fair Labor Standards Act (FLSA) and the New York Labor Law (NYLL).

Before this renewed motion, the court had granted in part and denied in part the defendants’ earlier summary-judgment motion. It granted the motion on all of Melendez’s NYLL claims except his claim that the defendants retaliated against him for complaining about unpaid minimum and overtime wages. It denied the motion on the FLSA claims because the defendants had not yet shown that the release resulted from a genuine dispute and compromise over hours and pay.

FLSA Claims

The defendants renewed their motion under Federal Rule of Civil Procedure 56, which permits summary judgment when there is no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. The motion was unopposed, but the court still independently considered whether the defendants had met their legal burden.

The court explained that employees generally cannot waive their FLSA rights to minimum wages, overtime pay, and related damages through a simple waiver. But an out-of-court release of FLSA claims can be enforced when it results from a genuine dispute between the employer and employee and a genuine compromise and settlement.

The court found that requirement satisfied. Before signing the release, Melendez claimed that he had worked more than 40 hours per week without receiving overtime pay. The defendants maintained that they had properly paid him for all hours worked. The court found that the parties negotiated at arm’s length, that Melendez initiated the discussions, and that the $7,500 payment was the amount he sought. The court also noted that Melendez had indicated he was prepared to assert labor-law claims, had agreed that he had consulted with an attorney or waived the opportunity to do so, and had accepted the payment after negotiations. The court concluded that the release was not merely a waiver of statutory rights and covered all of Melendez’s FLSA claims.

Remaining NYLL Claim and Disposition

After resolving all federal claims, the court declined to exercise supplemental jurisdiction, meaning its authority to hear related state-law claims, over Melendez’s remaining NYLL retaliation claim. The court dismissed that claim without prejudice.

The court granted the defendants’ renewed motion for summary judgment on Melendez’s FLSA claims and dismissed the remaining NYLL claim without prejudice. The clerk was directed to close the motion and the case.