Narvaez v. Black Label Salon 25 Corp
- Edgardo Ramos
- 1:20-cv-04465
- U.S. District Court · Southern District of New York
- 3
In Narvaez v. Black Label Salon, Judge Ramos approved the parties’ $20,000 settlement of wage claims and closed the case.
Marina Narvaez and the named defendants—Black Label Salon 25 Corp., Connie Lee, and Seung Lee—were affected by approval of the $20,000 settlement and closure of the case.
What happened
In Narvaez v. Black Label Salon 25 Corp., Marina Narvaez alleged that the defendants violated federal and New York wage laws by failing to pay overtime and other required wages.
The court had previously denied settlement approval without prejudice because Narvaez had not supported her estimate of maximum damages. She later submitted a spreadsheet supporting an estimated maximum recovery of $45,260.
Judge Ramos found the $20,000 settlement fair and reasonable in light of the defendants’ disputed calculations and the risks of trial. He granted the parties’ motion for settlement approval and directed the Clerk of Court to close the case.
The detailed version
- Narvaez v. Black Label Salon 25 Corp · No. 1:20-cv-04465
- Edgardo Ramos
- Feb. 2, 2021
Background
Marina Narvaez brought the action individually and on behalf of all others similarly situated against Black Label Salon 25 Corp., doing business as Black Label Salon, Connie Lee, and Seung Lee. She asserted claims under the Fair Labor Standards Act (FLSA), New York Labor Law, and Title 12 of the New York Codes, Rules and Regulations. She alleged that the defendants failed to pay overtime and spread-of-hours wages, made unlawful deductions, failed to maintain proper records, and failed to pay her on time.
The parties sought approval of their proposed settlement. On February 1, 2021, the court denied the settlement-approval application without prejudice because the parties had not provided evidence supporting Narvaez’s estimate that her maximum possible recovery was $45,260. The court otherwise found the settlement fair and reasonable and directed the parties to provide supporting evidence.
Supplemental Submission
Narvaez submitted a spreadsheet showing the minimum-wage and overtime-premium rates for each year of her employment, the weekly wages she alleged she should have received based on her hours, and the amounts she was actually paid. The spreadsheet calculated approximately $33,858 in underpayment damages. It also calculated approximately $11,402 in damages under New York Labor Law sections 191, 195, and 198 for late payment and wage-notice and wage-statement violations. Together, these amounts supported the estimated maximum recovery of $45,260.
The court explained that FLSA claims cannot be privately settled with prejudice without approval from the district court or the Department of Labor. It therefore reviewed whether the agreement was fair and reasonable. The parties reported that the defendants disputed Narvaez’s damages calculations and believed she would recover little, if anything, at trial. Considering that litigation risk, the court found the $20,000 settlement fair and reasonable under the circumstances.
Disposition
Judge Edgardo Ramos granted the parties’ motion for settlement approval. The order directed the Clerk of Court to terminate Document 36 and close the case. The opinion does not state that the motion was granted with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.