Ramirez v. Sacrop Restaurant Corp.

Background

Valentin Rosendo Ramirez, Bautista Juarez Reynaldo, and Ricardo Placido sued their former employers, Sacrop Restaurant Corp. doing business as Taqueria Y Fonda, Umberto Tito, and Jorge Lopez Guerrero. They alleged violations of the Fair Labor Standards Act, the New York Labor Law, and the Wage Theft Prevention Act.

The parties submitted a settlement agreement and a letter explaining why the court should approve it. The proposed agreement required the defendants to pay $50,000 in total, including $13,332 in attorneys’ fees and costs. The plaintiffs would receive $36,668 after those fees and costs. They estimated that their unpaid-wage damages, without liquidated damages or Wage Theft Prevention Act damages, were approximately $36,028. The court noted that the settlement therefore represented approximately 102% of that unpaid-wage estimate.

Court’s analysis

The court found the settlement fair and reasonable. It relied on the parties’ arms-length negotiations, the involvement of experienced counsel, disputed factual issues, and the possibility that the plaintiffs could recover less at trial, including no liquidated damages. The court also approved the attorneys’ fees, concluding that the amount was reasonable in light of the settlement.

The court separately reviewed the settlement’s release and non-disparagement provisions. It found the release sufficiently limited because it covered claims raised in the lawsuit and claims the plaintiffs could have asserted under the Fair Labor Standards Act and New York Labor Law. It also found the non-disparagement provision acceptable because it allowed truthful statements about the employment relationship.

Disposition

Judge Ronnie Abrams approved the parties’ settlement agreement and the attorneys’ fees. The court dismissed the complaint with prejudice in accordance with the settlement agreement and directed the Clerk of Court to close the case.