Brabham v. Peace of Mind Technologies, LLC

Background

Horace Brabham sued Peace of Mind Technologies, LLC and Justworks Employment Group LLC. He alleged violations of the Fair Labor Standards Act (FLSA), various provisions of the New York Labor Law (NYLL), and the Family and Medical Leave Act (FMLA). His allegations included failure to pay overtime, failure to provide proper wage notices and statements, and entitlement to lost income, benefits, other damages, interest, and liquidated damages.

The parties jointly moved for approval of a settlement agreement. The agreement called for a total payment of $42,500. Brabham’s counsel would receive $14,536 in attorney’s fees and costs, leaving $27,964 for Brabham. Brabham estimated his maximum recovery at approximately $91,326, including unpaid overtime, wage-notice and wage-statement damages, and unpaid reimbursements.

Court’s Analysis

The court explained that, in the Second Circuit, private settlements of FLSA claims that end those claims require approval by the court or the Department of Labor. The court therefore evaluated whether the agreement was fair and reasonable under the circumstances, including the possible recovery, litigation risks and costs, the parties’ negotiations, and the possibility of fraud or collusion.

The court found the settlement amount fair and reasonable. The parties had contested the hours Brabham claimed to have worked and the period of his employment. Defendants also raised exemption issues and disputed whether certain on-call time was compensable. The court concluded that the agreement resolved genuine disputes and reflected a reasonable compromise reached through arm’s-length negotiations by attorneys experienced in wage-and-hour litigation.

The court also approved the attorney’s fees and costs. Counsel sought $14,536, including $13,981 in fees. Attorney Abdul K. Hassan submitted records showing 20.99 hours of work at an hourly rate of $500, producing a lodestar—a calculation based on a reasonable hourly rate multiplied by reasonable hours—of $9,926.14. The requested fees represented a multiplier of approximately 1.41 over that lodestar. The court found the hourly rate and multiplier reasonable under the circumstances.

The court found the remaining settlement terms fair and reasonable as well. It determined that the release was limited to wage-and-hour allegations, including claims under the FLSA and NYLL, and related wage claims. The agreement contained no objectionable release, confidentiality provision, or non-disparagement provision.

Disposition

The court granted the motion for settlement approval. It directed the clerk to terminate the motion and close the case. The opinion does not state that the court decided whether Brabham’s underlying wage or leave-law allegations were valid; it approved the parties’ settlement instead.