Sealock v. Covance Market Access Services, Inc.

Background

The court considered the parties’ consent motion for final approval of a class and collective action settlement. The case involved wage-and-hour claims under the Fair Labor Standards Act (FLSA) and New York law. The court had previously granted preliminary approval, authorized notice, and certified a settlement class for purposes of the settlement.

The settlement covered two groups: (1) individuals who worked as clinical research associates in New York between August 3, 2011, and October 8, 2019, for purposes of the FLSA settlement; and (2) individuals who worked as clinical research associates in New York between August 3, 2014, and October 8, 2019, who did not request exclusion from the New York class settlement and who cashed a settlement check.

Court’s Findings

The court found that the notice provided to class members was the best practicable notice under the circumstances and complied with the federal class-action rule and due process. It found that the parties had investigated the facts and law, exchanged sufficient discovery, and had enough information to evaluate the claims, defenses, and settlement.

The court approved two settlement funds. A gross fund of $183,095.20 was allocated to the FLSA plaintiffs, with a net fund of $76,455.88 to be distributed to those who did not opt out. A gross fund of $66,904.80 was allocated to the New York class plaintiffs, with a net fund of $29,557.25 to be distributed. The order stated that payments would depend in part on whether a claimant was designated in the defendant’s records as a highly compensated employee. It directed the claims administrator to distribute payments to 170 participating class members.

The settlement provided John Sealock, the named plaintiff, a $10,000 service award. The court granted class counsel’s request for $83,333 in attorneys’ fees and $17,253.86 in expense reimbursement. It also provided for $20,000 in fees and costs for Arden Claims Service, LLC, the claims administrator.

Ruling and Disposition

Judge Jesse Furman granted final approval of the settlement and ordered the parties to comply with its terms. The court found the settlement fair, reasonable, adequate, and in the best interests of the settlement classes. The court stated that the settlement was not an admission of liability, fault, wrongdoing, or the truth of any allegation.

The named plaintiff and participating plaintiffs, except Stephanie Denise Bailey, were bound by the settlement. The order released covered New York wage-and-hour claims and FLSA wage-and-hour claims. Rule 23 plaintiffs who cashed their settlement checks also released the covered FLSA claims. John Sealock separately released all claims arising from his employment in exchange for the service award.

The court dismissed all claims against the defendant with prejudice, directed the Clerk to close the case, and entered final judgment. It retained exclusive and continuing jurisdiction over the settlement’s interpretation, implementation, enforcement, and administration.