Santiago v. City of New York
- Sarah Cave
- 1:24-cv-06254
- U.S. District Court · Southern District of New York
- 3
In Jacob Santiago v. City of New York, Judge Cave required more expense records before reviewing the parties’ wage settlement.
The order directly affects the plaintiffs’ counsel, who must submit documentation supporting the requested litigation expenses. It also affects the plaintiffs and the City of New York because the court’s review of their proposed FLSA settlement remains incomplete.
What happened
Jacob Santiago and the other plaintiffs brought a wage-and-hour case against the City of New York under the Fair Labor Standards Act. The parties asked the court to approve their proposed settlement, which included payments to the plaintiffs and deductions for litigation expenses and attorneys’ fees.
The court explained that it must evaluate whether fees and costs included in an FLSA settlement are reasonable. Plaintiffs’ counsel did not provide receipts, invoices, or similar records supporting the requested litigation expenses.
Judge Sarah L. Cave ordered plaintiffs’ counsel to submit appropriate documentation for the requested costs by September 19, 2025. The order did not state that the settlement was approved or denied.
The detailed version
- Santiago v. City of New York · No. 1:24-cv-06254
- Sarah Cave
- Sept. 12, 2025
Background
The plaintiffs and the City of New York are parties to a wage-and-hour case under the Fair Labor Standards Act (FLSA), a federal law governing certain wages and working hours. The parties consented to Magistrate Judge Sarah L. Cave’s jurisdiction and submitted a proposed settlement for court approval.
The proposed settlement provided for litigation expenses and attorneys’ fees to be deducted before distributing the plaintiffs’ share of the settlement. Plaintiffs’ counsel submitted fee and cost information but did not provide documentation supporting the requested litigation expenses.
Court’s analysis
The court stated that when an FLSA settlement includes attorneys’ fees and costs, the court evaluates whether those amounts are reasonable. Applicants seeking fees and costs must provide adequate supporting documentation. The court noted that receipts or invoices were needed to review the proposed litigation expenses.
Ruling
The court did not approve or deny the proposed settlement in this order. Instead, Judge Cave ordered plaintiffs’ counsel to submit, by September 19, 2025, appropriate cost documentation corresponding to the amount requested in the proposed settlement. The court stated that without this documentation it could not complete its review.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.