Mangahas v. Eight Oranges Inc.

Background

Jessy Mangahas and Pitchaya Wohlfahrt brought this case under the Fair Labor Standards Act, a federal law governing wage and hour matters, on behalf of themselves and others similarly situated. The defendants are Eight Oranges Inc., doing business as The Bao; Chibaola Inc., doing business as Uluh; Joanne Hong Bao; and Richard Lam. The parties informed the court that they had reached a settlement in principle.

Court’s directives

Under Second Circuit law, the court must review a Fair Labor Standards Act settlement, including any proposed attorney’s fee award, to determine whether it is fair. The court ordered the parties to submit a joint letter by July 10, 2025, explaining the basis for the proposed settlement and why it should be approved as fair and reasonable. The letter must address the fairness factors identified in Wolinsky v. Scholastic, Inc., as well as any confidentiality provisions, non-disparagement provisions, and releases in the proposed agreement.

If the settlement includes an attorney’s fee award, the parties must also address that award and provide supporting documentation when appropriate. The court stated that merely identifying the percentage of the settlement requested as fees is not enough. The fee request should normally be supported by contemporaneous time records showing, for each attorney, the date, hours worked, and nature of the work. The court warned that inadequate documentation could lead it to reject the proposed fee award.

Hearing and disposition

The court directed the parties to appear by telephone for a settlement fairness hearing on July 17, 2025, at 3:00 p.m. The named plaintiffs were requested to attend and, if necessary, to use an interpreter. The court dismissed any pending motions as moot and canceled all conferences and deadlines, including trial and pretrial deadlines. The order required further review of the proposed settlement; it did not state that the settlement had been approved.