Bell v. Equinox Holdings, Inc.

Background

Denys Bell sued his former employer, Equinox Holdings, Inc., under the Fair Labor Standards Act (FLSA) and the New York Labor Law. Bell worked as a maintenance associate at Equinox fitness clubs in New York. He alleged that he and similarly situated workers performed manual labor for more than 25% of their working hours and were not paid weekly or within seven calendar days after the end of the workweek, as he contended New York law required. He sought injunctive relief, liquidated damages, and attorney’s fees and costs.

Bell’s complaint described the case as a collective action, but no collective action was certified and no other plaintiff joined the case.

Settlement Review

The parties asked the court to approve their proposed settlement under the requirement that courts review FLSA settlements. Equinox agreed to pay a total of $15,000. Bell’s net payment would be $9,730, and $5,270 would go to his counsel for fees and costs.

Bell estimated that his potential FLSA recovery at trial was approximately $33,800, or approximately $50,700 if a jury found the violation willful and applied a three-year limitations period. The court concluded that Bell faced significant litigation risks, including uncertainty about liquidated damages under a recent amendment to New York Labor Law § 198 and disagreement among courts about whether delayed payment alone violates the FLSA’s prompt-payment requirement. The court therefore found the settlement amount reasonable in light of the risks.

The court also found that the agreement was negotiated competently, in good faith, and at arm’s length, with no fraud or collusion. Because Bell was the only employee affected by the settlement and no other employee joined the case, the court considered that circumstance supportive of approval.

Release and Attorney Fees

The court approved the release because it covered claims under the FLSA, New York Labor Law, and other laws relating to the payment of wages. The court explained that an FLSA settlement cannot generally release unrelated claims, but found that this release was limited to wage-related matters.

The court also approved $5,270 in attorney’s fees and costs. Counsel supported the request with time records and hourly rates. Peter A. Romero recorded 10.4 hours at $450 per hour, and David D. Barnhorn recorded 1.7 hours at $350 per hour. The court found the rates reasonable and noted that the requested amount was consistent with the lodestar calculation, meaning the reasonable hourly rates multiplied by the reasonable hours worked.

Disposition

The court granted the parties’ request for approval of the Settlement Agreement and directed the Clerk of Court to close the case.