Prudente v. Prohealth Connect, LLC

Background

Yuly Prudente and Prohealth Connect, LLC, along with other defendants, sought approval of a proposed settlement in a case involving claims under the Fair Labor Standards Act (FLSA). The court explained that it could approve the FLSA settlement only if the parties’ submissions showed that it was fair and reasonable.

Prudente’s supporting letter stated that the total settlement amount was $30,000. The settlement agreement, however, described the amount in words as “Twenty Thousand Dollars and Zero Cents” while stating the numerical amount as $30,000. The court found that this appeared to be a typographical error and required a corrected agreement.

Information the Court Found Missing

The supporting materials estimated approximately $78,600 in unpaid overtime wages under the six-year New York limitations period, including approximately $52,200 under the two-year FLSA period for non-willful violations. The letter also referred to approximately $32,750 in unpaid expense-reimbursement claims. It stated that defendants disputed the alleged work hours and maintained that Prudente was properly compensated for hours worked.

The parties also disputed whether certain on-call time was compensable under the FLSA and the New York Labor Law, and whether Prudente was an employee or an independent contractor. The materials stated that defendants might avoid liquidated damages through a good-faith defense, but did not clearly say whether Prudente was claiming FLSA liquidated damages. Because liquidated damages could double the claimed recovery, the court found that this uncertainty prevented it from determining the total alleged damages.

The court further found that the $30,000 settlement covered both FLSA and non-FLSA claims, but the parties did not identify how much of the settlement was allocated to the FLSA claims. The court noted that the New York Labor Law claims did not require court approval, while the FLSA settlement did. The parties also did not provide each side’s estimate of the number of hours worked and the applicable wage, as required when the parties disagree about the wages owed.

Order

The court did not approve the settlement at that time. Judge Vernon S. Broderick ordered the parties to submit, no later than February 19, 2025, a corrected settlement agreement and a joint letter addressing the deficiencies. The joint letter must provide each party’s estimate of Prudente’s hours and applicable wage for the FLSA claim, identify the portion of the total settlement allocated to the FLSA claim, and state whether Prudente is claiming liquidated damages under the FLSA.