Benjamin v. City of New York
- Ricardo
- 1:23-cv-05458
- U.S. District Court · Southern District of New York
- 2
In Benjamin v. City of New York, Judge Ricardo approved the parties’ Fair Labor Standards Act settlement and dismissed the case with prejudice.
The plaintiffs and the City of New York, whose FLSA wage-and-hour dispute was resolved through the approved settlement.
What happened
Benjamin v. City of New York was a damages case under the Fair Labor Standards Act, a federal wage-and-hour law. The parties asked the court to approve their settlement agreement.
The court reviewed the agreement and the parties’ submissions, including the risks and costs of continuing the case, possible recovery, attorney’s fees, and the possibility of fraud or collusion. It noted that the agreement had no confidentiality restrictions, narrowly released wage-and-hour claims, and provided reasonable attorney’s fees.
Judge Henry J. Ricardo found the settlement fair and reasonable, approved it, and dismissed and discontinued the case in its entirety with prejudice. The court retained limited authority to enforce the settlement agreement and directed the clerk to close the case.
The detailed version
- Benjamin v. City of New York · No. 1:23-cv-05458
- Ricardo
- Feb. 10, 2025
Background
The plaintiffs brought an action for damages under the Fair Labor Standards Act (FLSA), a federal wage-and-hour statute, against the City of New York. The parties consented to have the case decided by a United States magistrate judge under 28 U.S.C. § 636(c).
The parties jointly asked the court to approve their settlement agreement. They submitted a fully executed agreement on September 9, 2024, along with declarations from Diana J. Nobile and Hope A. Pordy.
Settlement Review
The court explained that it had to determine whether the FLSA settlement was fair and reasonable and resulted from arm’s-length negotiations rather than employer overreaching. The court considered the prior proceedings, the risks, burdens, and costs of continuing the case, the possible range of recovery, whether the agreement resulted from arm’s-length bargaining, the attorney’s fees, and the possibility of fraud or collusion.
The court noted that the settlement contained no confidentiality restrictions, narrowly limited the release to wage-and-hour claims, and provided attorney’s fees within a fair and reasonable range. Based on all the circumstances, the court found the agreement fair and reasonable.
Ruling
Judge Henry J. Ricardo approved the settlement agreement. Because the case had been resolved by settlement, the court dismissed and discontinued it in its entirety, with prejudice, without costs or fees to any party except as provided in the settlement agreement. The court retained jurisdiction for the limited purpose of enforcing the settlement agreement, terminated the remaining motions and deadlines, and directed the clerk to close the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.