Flores v. Masterpiece Caterers Corp.
- Lorna Schofield
- 1:19-cv-04059
- U.S. District Court · Southern District of New York
- 2
In Flores v. Masterpiece Caterers Corp., Judge Schofield did not approve the proposed Fair Labor Standards Act settlement and required revisions to its release and fee support.
Ana Maria Flores, the remaining defendants, and Plaintiff’s counsel were affected. The proposed settlement was not approved in its current form, and the parties were required to submit additional records and revisions.
What happened
In Flores v. Masterpiece Caterers Corp., Ana Maria Flores alleged violations of the Fair Labor Standards Act and New York Labor Law. India House, Inc. was dismissed without prejudice, and Flores later notified the court that the remaining parties had reached a settlement.
The parties asked the court to approve their proposed settlement as fair and reasonable. The court identified two problems: the release was too broad because it covered claims beyond Flores’s wage-related claims, and her counsel had not provided records supporting the proposed $3,133.30 fee payment.
Judge Lorna G. Schofield did not approve the settlement in its current form. She ordered the parties to file counsel’s billing records and an amended or revised settlement addressing the problems by February 4, 2020.
The detailed version
- Flores v. Masterpiece Caterers Corp. · No. 1:19-cv-04059
- Lorna Schofield
- Jan. 27, 2020
Background
Ana Maria Flores filed a complaint alleging violations of the Fair Labor Standards Act (FLSA) and the New York Labor Law. India House, Inc. was dismissed without prejudice. The remaining parties later notified the court that they had reached a settlement and submitted a proposed settlement agreement and joint letter seeking approval.
Court’s analysis
The court reviewed the proposed settlement under the requirement that an FLSA settlement be fair and reasonable. It found that the agreement’s general release was unreasonably broad. The release would have required Flores to give up claims of every kind connected in any way with her employment, including unknown claims and claims unrelated to wage-and-hour issues. The court directed that any new or amended agreement limit the release to Flores’s wage-related claims.
The court also found that Plaintiff’s counsel had not provided timesheets, billing records, or other information supporting the agreement’s provision of $3,133.30 in attorneys’ fees.
Disposition
The court ordered that the settlement agreement was not approved in its current form. It ordered the parties to file Plaintiff’s counsel’s billing records and any amended or revised settlement agreement addressing the identified deficiencies by February 4, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.