Huggins v. Wiener

Background

Alejandro Huggins brought this Fair Labor Standards Act (FLSA) and New York Labor Law case for himself and similarly situated employees. The plaintiffs were employed by certain defendants as building superintendents. They alleged that the defendants failed to pay minimum and overtime wages and failed to satisfy New York’s statutory notice and recordkeeping requirements.

The court conditionally certified the case as an FLSA collective action in May 2020. Eighteen plaintiffs opted into the collective. The parties conducted significant discovery, and Huggins and Clinton Jack were deposed in May 2021. All 18 plaintiffs signed the proposed settlement agreement.

Settlement terms and court’s analysis

Because the parties sought a stipulated dismissal under Federal Rule of Civil Procedure 41, the court was required to review and approve the FLSA settlement. The court examined the settlement’s overall payment, attorney’s fees and costs, and release of claims.

The agreement required the defendants to pay $250,000. It allocated $149,456.23 to the 18 plaintiffs on a proportional basis, $12,500 in service awards to Huggins and Jack, $83,333.33 in attorney’s fees, and $4,710.44 in costs. According to the parties’ calculations, each plaintiff would receive at least 60% of the alleged unpaid wages, and the median recovery would be 87%. The court found those recoveries reasonable in light of the plaintiffs’ litigation risks, including their lack of records for most of the hours allegedly worked.

The court approved the service awards because Huggins and Jack responded to discovery and sat for full-day depositions, and Huggins also helped prepare the complaint and a declaration supporting conditional certification. The court also approved the attorney’s fees after comparing the requested $83,333.33 with a calculated hourly-value benchmark of $161,575.50. It approved the $4,710.44 in costs, which arose from notifying workers about certification and obtaining deposition transcripts.

The release covered claims arising from the same general facts described in the complaint and involving unpaid wages. The court found that the release was adequately limited to wage-related claims rather than releasing unrelated claims.

Ruling

Judge Paul A. Crotty found the settlement agreement fair and reasonable and GRANTED the parties’ request to approve it. The court stated that it would separately so-order the parties’ Stipulation and Order of Final Dismissal with Prejudice under Rule 41, and directed the Clerk of Court to close the case.