Matias v. City of New York
- Sarah Netburn
- 1:21-cv-01736
- U.S. District Court · Southern District of New York
- 3
In Matias v. City of New York, Judge Woods set procedures for dismissing Fair Labor Standards Act claims after the parties reported reaching a settlement.
Evelyn Matias and the other plaintiffs, the City of New York, and the New York City Police Department, because the order set the procedures for resolving and potentially dismissing their settled FLSA claims.
What happened
In Matias v. City of New York, the parties told the court that they had reached a settlement involving claims under the Fair Labor Standards Act, a federal wage-and-hour law.
The court explained that the parties had two options. They could seek court approval to dismiss the Fair Labor Standards Act claims with prejudice, meaning the claims could not be brought again, or they could submit an agreement dismissing those claims without prejudice, meaning the claims would not be barred from being brought again based on that dismissal.
Judge Gregory H. Woods directed the parties to follow specified filing and consent procedures. The court did not approve the settlement or dismiss the claims in this order.
The detailed version
- Matias v. City of New York · No. 1:21-cv-01736
- Sarah Netburn
- Sept. 27, 2021
Background
The parties advised the court that they had reached a settlement. The settlement included claims under the Fair Labor Standards Act (FLSA), a federal law governing certain wage and hour rights.
Court’s instructions
The court explained that, under the Second Circuit’s decision in Cheeks v. Freeport Pancake House, Inc., the parties could not dismiss FLSA claims with prejudice through the ordinary joint-dismissal procedure in Federal Rule of Civil Procedure 41(a)(1)(A). A dismissal with prejudice would bar those claims from being brought again. To obtain that type of dismissal, the parties had to seek court approval under Rule 41(a)(2).
The court first ordered the parties to discuss whether they would consent to having all further proceedings handled by the assigned magistrate judge. If both sides consented, they had to file the required consent and reference form within two weeks of the order. If either side declined, the parties had to file a joint letter within two weeks stating that they did not consent, without identifying the party or parties that declined. The court stated that withholding consent would not have negative consequences.
If the parties did not consent to proceedings before the magistrate judge, they had to submit a joint motion by October 22, 2021, explaining why the settlement was fair and should be approved. The motion had to address the factors identified in Wolinsky v. Scholastic Inc. and include the settlement agreement. The court stated that it would not approve settlement agreements containing confidentiality provisions and would not allow settlement-related filings to be placed under seal without a particularized showing overcoming the presumption of public access to judicial documents. If the settlement included attorney fees, the parties also had to address whether the fees were reasonable and provide detailed attorney time records.
Alternatively, the parties could submit, within two weeks, a stipulation dismissing the FLSA claims without prejudice under Rule 41(a)(1)(A). The court stated that it would accept such a stipulation if it dismissed the FLSA claims without prejudice.
Disposition
Judge Gregory H. Woods issued procedural instructions concerning possible dismissal of the FLSA claims. The order did not approve the settlement and did not itself dismiss the claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.