Lin v. Ginza 685 Inc

Background

Jia Wang Lin filed claims under the Fair Labor Standards Act and New York Labor Law. The parties later reported that they had reached a settlement and submitted the proposed agreement for court approval. The agreement provided for a total payment of $25,000, including attorney’s fees and costs.

The opinion states that Lin alleged $43,893 in New York Labor Law damages, including unpaid wages, overtime, spread-of-hours compensation, liquidated damages, statutory damages for notice and wage-statement violations, and prejudgment interest. The opinion notes a discrepancy in the cited figures: the parties’ joint letter stated $43,893.71, while Lin’s damages calculation stated $43,893.72. The defendants accepted Lin’s allegations about his employment period, hours, and compensation only for settlement purposes. They disputed their liability and argued that Lin was not entitled to liquidated damages because they had acted in good faith and had not willfully underpaid him.

Settlement Approval

The court applied the requirement that private settlements of Fair Labor Standards Act claims be reviewed and approved. A settlement must be a fair and reasonable compromise of disputed issues rather than an employer’s overreaching waiver of statutory rights.

The court found the $25,000 settlement reasonable in light of the genuine dispute over the extent of the defendants’ liability. It described the settlement amount as presumptively reasonable and approved it as a reasonable compromise of contested issues.

Attorney’s Fees and Costs

The opinion’s opening paragraph says that counsel sought $8,766.67 in fees and expenses. In the later fee discussion, however, the court states that counsel sought $8,116.67, described as one third of the settlement amount less costs. The court did not explain this discrepancy.

The court reviewed the fee request using the lodestar method as a cross-check. The lodestar is the reasonable hourly rate multiplied by the reasonable number of hours worked. The court found the proposed hourly rates excessive and reduced them to $400 for John Troy, $150 for Aaron Schweitzer, $100 for Maggie Huang, and $70 for Preethi Kilaru. It also found that approximately 80 hours was excessive for a case that settled less than seven months after filing, after limited discovery and before a motion for conditional collective certification. The court deducted 40% of the billed hours.

Using the reduced rates and hours, the court calculated a lodestar of $13,354. Because that amount was greater than the fee award included in the settlement, the court did not change the fee calculation. The court also found the requested $650 for filing and service costs reasonable and granted that request.

Disposition

Judge Alison J. Nathan approved the settlement agreement in full and directed the Clerk of Court to close the case. The opinion does not state that the court decided whether the defendants actually violated the wage laws; it approved the parties’ settlement instead.