Madariaga v. Mama Cat LLC

Background

The court was advised that the parties had reached a settlement involving claims under the Fair Labor Standards Act (FLSA). The order does not state the settlement’s terms or say that the court approved it.

Court’s directives

The court described three ways the parties could proceed:

1. Dismissal with prejudice under Rule 41(a)(2). Because the FLSA requires court review of a settlement when the parties seek to dismiss FLSA claims with prejudice, meaning in a way that generally bars refiling, the parties could ask the court to approve the proposed dismissal. They first had to discuss whether to consent to having all further proceedings handled by the assigned magistrate judge. If both sides consented, they had to file the required consent form by July 31, 2025. If either side withheld consent, the parties had to file a joint letter by that date without identifying the party or parties that did not consent. If the parties did not consent, they had to submit by August 12, 2025, a joint motion explaining why the settlement was fair, addressing the factors identified in Wolinsky v. Scholastic Inc., and attaching the settlement agreement.

The court stated that it would not approve settlement agreements containing confidentiality provisions. It also said that documents related to settlement review could not be filed under seal unless the parties made a specific showing that overcame the presumption of public access. If the settlement included attorney’s fees, the parties had to address whether the fees were reasonable under the framework identified in Goldberger v. Integrated Resources, Inc., and plaintiffs’ attorneys had to provide detailed time records.

2. Dismissal without prejudice under Rule 41(a)(1)(A). The parties could submit a dismissal that preserved the ability to refile the FLSA claims, but only if the dismissal was without prejudice and the parties certified that there had been no settlement of FLSA claims. The stipulation and certification were due by July 31, 2025. If the parties could not make that certification, the court directed them to seek review of the settlement under the first procedure.

3. Offer of judgment under Rule 68(a). The parties could resolve the case through a formal offer and acceptance of judgment. The court stated that judicial approval was not required for such an offer involving FLSA claims. Any executed offer and acceptance, along with a proposed judgment, was due by July 31, 2025.

Effect of the order

This was a procedural order establishing how the parties could complete a settlement involving FLSA claims. It did not decide the underlying claims, approve a settlement, dismiss the case, or state which option the parties ultimately selected.