De la Rosa v. Chestnut Holdings of New York Inc.
- Valerie Caproni
- 1:19-cv-00286
- U.S. District Court · Southern District of New York
- 2
In De la Rosa v. Chestnut Holdings, Judge Caproni declined to approve the proposed settlement because its release exceeded wage-and-hour claims.
The plaintiff, the defendants, and their counsel were affected: the proposed settlement was not approved, although the parties could submit a revised agreement limited to wage-and-hour claims.
What happened
De la Rosa v. Chestnut Holdings of New York Inc. involved a proposed settlement submitted for the court’s approval. The agreement provided a total recovery of $36,500, including $11,767.82 for the plaintiff’s counsel’s fees and costs.
The court found that the requested attorney’s fee of $10,549.34 and costs of $1,218.48 were reasonable. But the proposed agreement released claims broader than wage-and-hour claims.
Judge Valerie Caproni did not approve the settlement as fair and reasonable because of the release’s breadth. She said the court would be prepared to approve an agreement releasing all wage-and-hour claims and allowed the parties to submit a revised agreement by March 3, 2020.
The detailed version
- De la Rosa v. Chestnut Holdings of New York Inc. · No. 1:19-cv-00286
- Valerie Caproni
- Feb. 18, 2020
Background
Counsel for the parties submitted a proposed settlement agreement for the court’s approval under Cheeks v. Freeport Pancake House, Inc. The opinion states that the proposed settlement provided a total recovery of $36,500. It allocated $11,767.82 to the plaintiff’s counsel for fees and costs.
Fees and Costs
The requested attorney’s fee was $10,549.34, which the court described as approximately one-third of the lodestar amount. A lodestar is a fee calculation based on counsel’s billing rates and time spent. The court found the requested fee reasonable. It also found the requested costs of $1,218.48 reasonable.
Release Provision
The court determined that paragraph 3(a) of the proposed settlement contained a release broader than wage-and-hour claims. The opinion does not identify the specific wage-and-hour statutes or claims involved.
Ruling
The court ordered that the proposed settlement agreement was not approved as fair and reasonable because of the release’s breadth. Judge Valerie Caproni stated that the court would be prepared to approve a settlement releasing all wage-and-hour law claims. The parties could submit a revised settlement agreement consistent with the order by March 3, 2020, if they wished to proceed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.