Goutakolis v. Madison Global, LLC

Background

The parties jointly submitted a proposed settlement for approval in this Fair Labor Standards Act (FLSA) case. The opinion does not provide detailed allegations or explain the parties’ underlying wage-and-hour disputes.

Settlement-review standard

The court explained that a district court must scrutinize an FLSA settlement before entering judgment to determine whether it is fair and reasonable. The relevant considerations include the plaintiff’s possible recovery, the burdens and expenses the settlement avoids, litigation risks, whether experienced counsel negotiated at arm’s length, and the possibility of fraud or collusion. The court also noted that private settlements of FLSA claims require approval by the district court or the Department of Labor.

Court’s review and ruling

The court reviewed the parties’ joint letter dated February 11, 2021, the proposed settlement agreement, a Confidentiality Preference Agreement concerning the plaintiff’s non-wage-and-hour claims, and the plaintiff’s counsel’s time records. It found the proposed settlement, including its attorneys’ fees and expense award, fair and reasonable and compliant with the approval requirements described in the opinion.

The court dismissed the action with prejudice and without costs to either party. It stated that the action could be restored to the calendar of the undersigned judge if settlement payments were not completed within 300 days of the order. A party seeking to reopen the matter had to submit a letter application before the 300-day period expired. The Clerk of Court was directed to close the case.