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S.D.N.Y.Procedural orderFiled Mar. 11, 2020

Garcia v. 120 MP, LLC

Judge
James Oetken
Docket
1:18-cv-06408
Court
U.S. District Court · Southern District of New York
Pages
2
FlsaCivil Procedure
In one sentence

In Garcia v. 120 MP, LLC, Judge Oetken required a public filing explaining the proposed Fair Labor Standards Act settlement before dismissal with prejudice.

Who this affects

The parties to the Fair Labor Standards Act case, including Izael Garcia and the other plaintiffs and defendants, were required to submit public settlement materials and could not dismiss the action with prejudice without approval.

What happened

In Garcia v. 120 MP, LLC, the court was informed that the parties had reached a settlement in a Fair Labor Standards Act case. The order did not decide the underlying wage claims.

The parties were told they could not dismiss the case with prejudice unless the settlement was approved by the court or the Department of Labor. They had to file a letter motion and the settlement agreement on the public docket within 30 days.

Judge Oetken ordered the filing by April 9, 2020. The filing had to explain why the settlement was fair and reasonable, address any genuine dispute about hours or compensation, and state the attorney-fee request. Other deadlines, conferences, and the trial date were postponed without a new date.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Garcia v. 120 MP, LLC · No. 1:18-cv-06408
Judge
James Oetken
Date
Mar. 11, 2020

Background

The court stated that the parties had reached a settlement in this Fair Labor Standards Act case. The opinion does not provide the settlement amount or describe the underlying claims in detail.

Settlement-Approval Requirements

The court advised that the parties could not dismiss the action with prejudice based on their settlement unless the agreement was approved by either the court or the Department of Labor. A dismissal with prejudice would end the action and prevent the claims from being brought again. The parties had to file a letter motion and the settlement agreement on the public docket within 30 days of the order.

The letter motion had to explain why the proposed settlement was fair and reasonable. It also had to address five factors: the plaintiff’s possible recovery; the burdens and expenses the settlement would avoid; the seriousness of the parties’ litigation risks; whether experienced counsel negotiated the agreement at arm’s length; and the possibility of fraud or collusion. The filing also had to discuss whether there was a genuine dispute about the hours worked or compensation owed, and how much the plaintiff’s attorney would seek in fees. The court stated that, absent special circumstances, it would not approve an agreement filed under seal or in redacted form.

Ruling and Case Status

Judge J. Paul Oetken directed the parties to file a letter or stipulation meeting these requirements by April 9, 2020. The order did not approve or reject the settlement. It also postponed all other filing deadlines, conference dates, and the trial date without setting new dates.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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