Rubenstein v. Wings Media, LLC

Background

Catherine Rubenstein and Wings Media, LLC, doing business as Podopolo, reached a settlement resolving Rubenstein’s claims. Some claims arose under the Fair Labor Standards Act (FLSA), a federal wage-and-hour law, while others did not. The parties put their resolution of all claims in one settlement agreement and asked the court to approve the FLSA portion while keeping the agreement and parts of their approval request under seal.

Settlement Approval

The court found that the FLSA settlement was fair and reasonable considering the nature and scope of Rubenstein’s claims and the risks and costs of further litigation. The court noted that Rubenstein no longer worked for Wings Media and that the agreement’s mutual non-disparagement provision allowed her to speak truthfully about her experience prosecuting the FLSA claims and the claims themselves. The court therefore granted approval of the settlement to the extent court approval was required.

The court also granted approval of the attorney’s fees and costs to the extent they were attributed to the FLSA claims. It found no reason to reduce the fee because the fee was significantly less than the lodestar amount, there were no opt-in plaintiffs, the case was not a collective action, and the fee award was based on an agreement between Rubenstein and her attorney.

Sealing Requests

The court held that the strong presumption of public access to judicial documents prevented it from approving the request to seal the settlement agreement in its entirety. The defendants’ stated concerns about confidentiality and business interests were insufficient to overcome that presumption.

The court did allow limited redactions of the monetary terms for the non-FLSA claims, which were not subject to judicial approval. The parties were permitted to redact the total settlement amount, percentage allocations, and the amount for the non-FLSA claims from Paragraph 1(A), as well as all of Paragraphs 1(A)(II) and (III). The court denied the request to redact Paragraph 4. Thus, the sealing requests were granted in part and denied in part.

Ruling and Case Status

The parties were ordered to publicly file the settlement agreement and their joint approval letter within three business days, with the specified redactions and with the FLSA settlement amount and certain related information unredacted. The court stated that any modification of the settlement agreement would require court approval. The Clerk was directed to terminate the sealing motion and close the case, while the court retained jurisdiction for one week so the parties could complete the agreement and file a stipulation of dismissal.