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S.D.N.Y.Procedural orderFiled Feb. 1, 2021

Reyes v. Healthy Fresh Juice Inc.

Judge
Sarah Cave
Docket
1:20-cv-05452
Court
U.S. District Court · Southern District of New York
Pages
2
FlsaCivil ProcedureFee Petition
In one sentence

In Reyes v. Healthy Fresh Juice Inc., Judge Broderick ordered the parties to submit their FLSA settlement for fairness review.

Who this affects

The plaintiffs and defendants in the FLSA case were required to submit the settlement terms and a joint explanatory letter within 30 days. If the settlement included attorney’s fees, supporting billing records also were required.

What happened

In Reyes v. Healthy Fresh Juice Inc., the parties told the court they had reached a settlement in a Fair Labor Standards Act case. The court had not yet approved the settlement.

The court explained that the parties must provide the settlement terms so it can decide whether they are fair and reasonable. The parties also must submit a joint letter of no more than five pages addressing the relevant fairness factors.

Judge Vernon S. Broderick ordered the submissions within 30 days. If the settlement includes attorney’s fees, the parties must also provide records supporting the requested award.

The detailed version

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

Case
Reyes v. Healthy Fresh Juice Inc. · No. 1:20-cv-05452
Judge
Sarah Cave
Date
Feb. 1, 2021

Background

The court was advised that the parties had reached a settlement in this Fair Labor Standards Act (FLSA) case. The opinion does not state the settlement amount or provide the settlement’s terms.

Legal standard

The court explained that the parties could not privately settle FLSA claims with prejudice without approval from the district court or the Department of Labor. The court therefore had to determine whether the settlement was fair and reasonable. It said that this review considers the total circumstances, including the plaintiffs’ possible recovery, the burdens and expenses of continuing the case, the litigation risks, whether the agreement resulted from arm’s-length bargaining, and the possibility of fraud or collusion.

If the settlement included attorney’s fees, the court also had to separately assess whether those fees were reasonable. The parties had to provide factual support, including contemporaneous billing records showing each attorney’s dates, hours, and work performed.

Order

The court ordered the parties to provide the settlement terms within 30 days so it could determine whether they complied with the FLSA and reflected a reasonable compromise of disputed issues. It also ordered the parties to submit a joint letter of no more than five pages explaining why the settlement was fair and reasonable, including information about the five listed factors. If the agreement included attorney’s fees, the parties had to submit evidence supporting the fee award. The order did not approve or reject the settlement.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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