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S.D.N.Y.Procedural orderFiled Jan. 4, 2021

Brittle v. Netamorphosis, LLC

Judge
Edgardo Ramos
Docket
1:20-cv-03880
Court
U.S. District Court · Southern District of New York
Pages
1
FlsaCivil Procedure
In one sentence

In Brittle v. Netamorphosis, LLC, Judge Ramos said the case could not yet be dismissed and ordered submission of the settlement agreement.

Who this affects

Kirsten Brittle, Netamorphosis, LLC, and Lyde Spann, whose proposed dismissal was not approved at that point.

What happened

In Brittle v. Netamorphosis, LLC, Kirsten Brittle sued Netamorphosis, LLC and Lyde Spann under federal and New York wage laws. The court had previously stayed the case while the parties pursued arbitration.

The parties later asked to dismiss the case with prejudice based on their joint stipulation. The court explained that federal wage claims cannot be privately settled and dismissed with prejudice without approval from the court or the Department of Labor.

Judge Ramos said the case could not yet be dismissed because the required approval had not been obtained. He directed the parties to submit their proposed settlement agreement to the court by January 19, 2021.

The detailed version

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

Case
Brittle v. Netamorphosis, LLC · No. 1:20-cv-03880
Judge
Edgardo Ramos
Date
Jan. 4, 2021

Background

Kirsten Brittle brought claims against Netamorphosis, LLC and Lyde Spann under the Fair Labor Standards Act, a federal wage law, and the New York Labor Law. On June 17, 2020, the court granted the parties’ request to stay the case while they pursued arbitration.

On January 4, 2021, the parties filed a joint stipulation asking the court to dismiss the case with prejudice, meaning the case would be ended in a way that barred refiling the same claims.

Ruling

The court explained that, in the Second Circuit, parties cannot privately settle Fair Labor Standards Act claims with prejudice unless the district court or the Department of Labor approves the settlement. Because the parties had not obtained that approval, the court stated that the case could not yet be dismissed.

The court directed the parties to submit their proposed settlement agreement by January 19, 2021. The order did not dismiss the case.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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