Richardson v. Atlas Builders LLC
- Edgardo Ramos
- 1:20-cv-05756
- U.S. District Court · Southern District of New York
- 3
In Richardson v. Atlas Builders LLC, Judge Ramos approved the parties’ $30,000 wage-settlement agreement and dismissed the case with prejudice.
Clinton Richardson and the defendants—Atlas Builders LLC, Alexander Alexandrov, and Mikhail A. Yusim—were affected by approval of the $30,000 settlement and dismissal of the case with prejudice. The settlement resolved Richardson’s unpaid-overtime, wage-notice, and wage-statement claims.
What happened
Richardson v. Atlas Builders LLC involved Clinton Richardson’s claims for unpaid overtime under federal and New York wage laws, along with New York wage-notice and wage-statement claims. The parties asked the court to approve their settlement agreement.
The court had previously rejected the request because the parties had not provided enough support for their damages calculations. They later submitted a spreadsheet showing estimated wage damages of $24,529.08, including unpaid wages, liquidated damages, wage-related statutory damages, and interest.
Judge Edgardo Ramos found the revised agreement reasonable in light of the damages calculation and litigation risk, approved it, dismissed the case with prejudice, and directed the clerk to close the case.
The detailed version
- Richardson v. Atlas Builders LLC · No. 1:20-cv-05756
- Edgardo Ramos
- Oct. 26, 2020
Background
Clinton Richardson sued Atlas Builders LLC, Alexander Alexandrov, and Mikhail A. Yusim, jointly and severally, over alleged unpaid overtime under the Fair Labor Standards Act (FLSA) and the New York Labor Law (NYLL). The case also included claims under New York’s wage-notice and wage-statement requirements. Richardson brought the case individually and on behalf of others similarly situated.
The parties submitted an agreement for court approval on October 1, 2020. The court rejected that application without prejudice on October 2 because the parties had not provided enough evidence supporting their damages calculations or showing the possible range of recovery. The court stated that the proposed attorney’s fees and release language were reasonable if the parties could establish that the settlement amount itself was reasonable.
Settlement analysis
In their renewed application, the parties submitted a spreadsheet explaining their calculations. The spreadsheet showed $6,405 in unpaid-wage damages, based on Richardson’s recollection of his hours and his different hourly and overtime rates. It also showed $6,405 in liquidated damages under the FLSA and NYLL, $5,000 in statutory wage-notice damages, $5,000 in statutory wage-statement damages, and $1,719.08 in statutory interest on the NYLL claims. The total wage-damages figure was $24,529.08.
The court noted that the parties included liquidated damages under only one statute because double recovery of liquidated damages under both statutes for the same conduct is not allowed. Considering the damages calculation and the litigation risk faced by the parties, the court found the proposed $30,000 settlement reasonable. It concluded that the revised agreement complied with the required settlement-review standard and approved it.
Disposition
The court approved the revised settlement agreement, dismissed the case with prejudice, and directed the clerk to close the case. Judge Edgardo Ramos entered the order on October 26, 2020.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.