Cameron v. Prosegur Services Group, Inc.

Background

Dale Cameron brought this action under the Fair Labor Standards Act, a federal law governing wages and working hours, against Prosegur Services Group, Inc. The parties informed the court that they had agreed to settle. The court then required them either to explain the status of their discussions or submit the settlement for judicial approval.

Settlement Review

The court reviewed Cameron’s request for approval under the standard requiring judicial review of Fair Labor Standards Act settlements. It found the settlement fair and reasonable, considering the nature and scope of Cameron’s individual claim and the risks and expenses of continued litigation. The court also noted that Cameron no longer worked for Prosegur, reducing concerns that the settlement or release was obtained through job-related pressure.

Fees and Costs

Cameron requested approval of $10,507 in attorney’s fees after costs. That amount represented one-third of the $31,522 net settlement amount. The court found the fee reasonable because fees in this circuit commonly range from 30% to 33% and the requested amount was consistent with the relevant contingency-fee arrangement and marketplace practice discussed in the opinion.

Cameron’s attorney also requested $402 in filing fees and $76 for service of process, for total costs of $478. The court noted that the signed settlement agreement incorrectly listed total costs of $481. Based on the submitted receipts and Cameron’s letter, the court approved costs of $478.

Ruling

The court approved the settlement subject to the condition that any modification of the settlement agreement must receive court approval, even if the agreement purported to allow the parties to modify it without court approval. The court dismissed the case with prejudice, ruled that all pending motions were moot, and directed the Clerk of Court to close the case.