Bronston v. County of Alameda

Background

Aram Bronston worked for the County of Alameda’s Emergency Medical Services Agency from November 19, 2018, through August 21, 2020. He served as an Emergency Medical Services Coordinator and as the Regional Disaster Medical Health Specialist for a region consisting of sixteen Northern California counties.

Bronston claimed that the County improperly classified his position as exempt from the Fair Labor Standards Act’s overtime requirement. That law generally requires covered employers to pay one-and-a-half times an employee’s regular rate for work beyond 40 hours in a workweek. Bronston claimed that he worked approximately 1,400 overtime hours.

The County argued that Bronston’s position qualified for the Act’s administrative and highly compensated employee exemptions. The parties disputed whether his duties related directly to the County and State’s general business operations, whether he exercised discretion and independent judgment on significant matters, whether the County acted in good faith, and how many overtime hours he worked.

The County had previously sought summary judgment, asking the court to rule that Bronston was exempt from overtime requirements. On August 15, 2021, the court denied that motion because genuine factual disputes remained. The court later referred the case to Magistrate Judge Donna Ryu for a settlement conference, which occurred on November 7, 2022.

Settlement Approval

The parties jointly asked the court to approve their settlement and permit a stipulated dismissal. The court explained that employees cannot privately waive Fair Labor Standards Act claims and that such claims may be settled only under the supervision of the Labor Department or a district court.

The court found that the proposed agreement represented approximately 71% of the overtime pay Bronston claimed and approximately 74% of the attorney fees and costs he claimed would have been recoverable as of the settlement conference if the case proceeded to trial. Because the case involved disputed legal and factual issues, the court found the agreement to be a fair and reasonable compromise of a genuine dispute.

Disposition

The court granted the parties’ joint motion to approve the proposed settlement agreement. It permitted the parties to file a voluntary dismissal with prejudice—a dismissal that permanently resolves the action—after Bronston received the settlement payment. The opinion does not state the settlement’s dollar amount.