Woll v. West Publishing Corporation
- Katherine Menendez
- 0:19-cv-00295
- U.S. District Court · District of Minnesota
- 2
In Woll v. West Publishing Corporation, Judge Menendez approved the parties’ confidential settlement of Molly Woll’s overtime claims.
Molly Woll and West Publishing Corporation; the order approved their settlement of disputed overtime and liquidated-damages claims.
What happened
In Woll v. West Publishing Corporation, Molly Woll alleged that West Publishing Corporation violated federal and Minnesota overtime laws and another Minnesota wage statute. West had offered backpay after reclassifying positions, but the parties disputed the overtime calculation, the number of hours, and liquidated damages.
The court found a genuine dispute and determined that the settlement was fair and reasonable. The court did not disclose the settlement’s confidential terms and granted the parties’ joint motion for settlement approval.
Judge Menendez entered the order approving the settlement on August 23, 2019. The order resolved the request for approval but did not decide which side would have prevailed on the underlying wage claims.
The detailed version
- Woll v. West Publishing Corporation · No. 0:19-cv-00295
- Katherine Menendez
- Aug. 23, 2019
Background
Molly Woll brought claims against her former employer, West Publishing Corporation, under the Fair Labor Standards Act, the Minnesota Fair Labor Standards Act, and Minn. Stat. § 181.13. After Woll left West, the company reclassified many positions, including Woll’s former position, as non-exempt and voluntarily offered backpay for overtime hours worked during the preceding two years.
Woll submitted her hours but filed this action while West was verifying them. She sought payment at 1.5 times her hourly rate for all submitted overtime hours, rather than the 0.5-times rate West had offered to newly non-exempt employees. She also sought liquidated damages. West argued that Woll’s proposed calculation was incorrect and that the fluctuating-workweek method supported the 0.5-times calculation. West also opposed liquidated damages.
Court’s analysis
The parties settled at a July 10, 2019 settlement conference. They jointly asked the court to approve the settlement because it was uncertain in the Eighth Circuit whether private Fair Labor Standards Act settlements require judicial approval.
The court applied the standard requiring an actual dispute and a fair and reasonable settlement. It identified disputes about the number of overtime hours Woll worked, the method for calculating overtime damages, and whether liquidated damages were appropriate. The court therefore found that a genuine dispute existed.
The court also reviewed the settlement’s fairness and reasonableness. It considered the relevant factors, including the stage of the case, discovery, the likelihood of success, counsel’s experience, possible employer overreaching, and whether the parties negotiated at arm’s length. The court stated that the settlement agreement was confidential and therefore did not describe its specific terms. It found the settlement fair and reasonable, noting that the parties were represented by experienced counsel and negotiated at arm’s length during a court-mediated settlement conference.
Disposition
The court GRANTED the parties’ Joint Motion for Settlement Approval. The order approved the settlement; it did not decide the underlying overtime claims or disclose the settlement amount or other confidential terms.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.