Laguna Chacon v. Cooks
- Rochon
- 1:23-cv-03056
- U.S. District Court · Southern District of New York
- 1
In Laguna Chacon v. Cooks, Judge Rochon required the parties to clarify whether they settled Fair Labor Standards Act claims before dismissal.
Gerardo Laguna Chacon, Albert Cooks, and Fish Chips & Grits Corp., whose proposed voluntary dismissal was subject to the court’s required FLSA settlement certification or review.
What happened
Gerardo Laguna Chacon sued Albert Cooks and Fish Chips & Grits Corp., and the parties submitted a joint agreement to voluntarily dismiss all claims and counterclaims with prejudice.
Because the case involved claims under the Fair Labor Standards Act, the court required the parties to confirm whether they had reached a settlement. The parties must file a joint letter by June 23, 2025, stating that no settlement occurred or requesting court review of any settlement.
Judge Jennifer L. Rochon did not simply accept the proposed dismissal at that point. She ordered the parties to provide the required certification or request review of their settlement.
The detailed version
- Laguna Chacon v. Cooks · No. 1:23-cv-03056
- Rochon
- June 16, 2025
Background
The parties submitted a joint stipulation asking to voluntarily dismiss all claims and counterclaims in the action with prejudice under Federal Rule of Civil Procedure 41(a)(1)(A)(i). The opinion states that the Fair Labor Standards Act (FLSA) was implicated.
Court’s Action
The court explained that a district court must inquire into whether the parties reached an FLSA settlement, even when the parties say they have dismissed the case. The court therefore ordered the parties to file a joint letter by June 23, 2025, certifying that no FLSA claims were settled.
If the parties could not make that certification, the court ordered them to request review of the settlement under the procedure associated with Cheeks v. Freeport Pancake House, Inc. The opinion does not state that the proposed dismissal was entered at this stage; it instead sets these additional requirements.
Disposition
Judge Jennifer L. Rochon ordered the parties to file the required certification or request settlement review. The order does not state a separate disposition of the voluntary-dismissal stipulation.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.