Camacho v. Midtown Center Auto Repair Inc.
- Lewis Liman
- 1:19-cv-09505
- U.S. District Court · Southern District of New York
- 3
In Camacho v. Midtown Center Auto Repair Inc., Judge Liman approved an FLSA settlement, fees, and costs, then dismissed the case with prejudice.
Francisco Camacho, the defendant parties, and Camacho’s attorneys were affected by the approved settlement, fee award, and dismissal with prejudice.
What happened
Camacho v. Midtown Center Auto Repair Inc. involved Francisco Camacho’s wage claim under the Fair Labor Standards Act. The parties reached a settlement and asked the court to approve it.
The court requested more information about the proposed settlement, attorneys’ fees, costs, and any wage records. The defendants said they had no wage-and-hour records for Camacho, so the parties relied on his memory to estimate hours and unpaid wages. The defendants also identified possible defenses and counterclaims that could have reduced or eliminated Camacho’s recovery.
Judge Lewis J. Liman found the settlement fair and reasonable. He approved the $50,000 settlement, including $16,500 in attorneys’ fees and $456 in costs, dismissed the case with prejudice, and directed the Clerk to close the case.
The detailed version
- Camacho v. Midtown Center Auto Repair Inc. · No. 1:19-cv-09505
- Lewis Liman
- Mar. 5, 2020
Background
Francisco Camacho brought the action under the Fair Labor Standards Act, a federal law governing wages and overtime pay. The parties informed the court that they had reached a settlement and submitted the settlement agreement and supporting letter for approval.
The court held a telephone conference and then ordered the parties to provide additional information. The requested materials included time records supporting the attorneys’ fee request, records supporting litigation costs, further explanation of why the amount Camacho would receive after fees and costs was fair and reasonable, and any wage-and-hour records maintained by the defendants.
The defendants represented that they had not maintained wage-and-hour records for Camacho during the relevant period. The parties therefore allowed Camacho to estimate his hours worked and wages owed based on his memory, and the defendants did not object to that estimate. The defendants also produced evidence they said supported a faithless-servant defense. They argued that this defense could have eliminated Camacho’s overtime claim and required him to repay wages earned during two of the three relevant years. The defendants also intended to bring counterclaims seeking money they claimed Camacho stole during his employment.
Court’s Analysis
After reviewing the settlement agreement, the parties’ letters, and the supplemental materials, the court found the settlement fair and reasonable in light of the nature and scope of Camacho’s individual claims and the risks and costs of continued litigation.
The court separately reviewed the request for $16,500 in attorneys’ fees and $456 in costs. It considered counsel’s success, the work performed, the time spent, whether that time was reasonable for the case, the factors identified in relevant precedent, the parties’ agreement, and fee percentages typically approved in the district. The court noted that the fee request was approximately one-third of the $50,000 settlement, within the 30% to 33% range it said courts in the district typically approve. The court found the work and hours reasonable and approved the fees and costs.
Ruling
Judge Lewis J. Liman approved the settlement and approved $16,500 in attorneys’ fees and $456 in costs. The court dismissed the case with prejudice and directed the Clerk of Court to close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.