Chase Morris v. United States Postal Service

Background

Cherlene Chase Morris sued the United States Postal Service (USPS) and the National Associate of Letter Carriers (NALC). She alleged that USPS did not pay her for certain overtime, other hours worked, authorized sick leave, and wages that had already been paid but later taken back. She also alleged that USPS terminated her employment after she complained to supervisors about her pay. The opinion notes that Morris brought separate New York City Human Rights Law claims against NALC.

Morris worked for USPS as a city carrier from July 2013 through August 2017. She filed the case on March 2, 2018, and later amended her complaint to add NALC. The claims at issue in the proposed settlement with USPS were claims under the Fair Labor Standards Act, a federal law governing matters such as overtime pay and retaliation for raising wage complaints.

Settlement Approval

Morris and USPS jointly asked the court to approve their settlement under the requirement that courts review settlements resolving Fair Labor Standards Act claims. The proposed settlement totaled $26,883. Morris would receive $17,922, and her attorney would receive $8,961 in fees. Morris had alleged a maximum recovery from USPS of approximately $64,928.80, consisting of $1,000 in unpaid wages and $63,928.80 in back pay.

The court considered the possible recovery, the burdens and risks of continued litigation, the parties’ negotiations, and the possibility of fraud or collusion. It found the settlement reasonable because it represented approximately 42 percent of Morris’s alleged maximum damages, exceeded her alleged unpaid wages, and allowed the parties to avoid the expense and uncertainty of trial. The court noted factual disputes concerning USPS’s timekeeping practices and the timing of Morris’s removal, as well as risks to Morris from expected testimony by current USPS employees.

The court also found that the agreement resulted from months of arm’s-length negotiations by experienced employment lawyers and included mediation. It found no evidence of fraud or collusion. The release was limited to claims based on Morris’s employment with USPS. The agreement had no confidentiality or non-disparagement provision. The court found the $8,961 fee award reasonable, although it questioned the appropriateness of the attorney’s claimed $700 hourly rate and noted that the attorney had reported discounting some time.

Ruling

The court approved the proposed settlement as fair and reasonable. Judge Ona T. Wang ordered that the action be dismissed with prejudice against USPS and without costs. The Clerk was directed to close the joint settlement-approval motion. The opinion does not state what disposition, if any, was entered on Morris’s claims against NALC.