Fritz v. Manhattan Beer Distributors LLC
- Lorna Schofield
- 1:21-cv-04727
- U.S. District Court · Southern District of New York
- 2
In Fritz v. Manhattan Beer Distributors LLC, Judge Schofield found no basis to reject the settlement and gave the parties one week to withdraw.
Lambert Fritz and Manhattan Beer Distributors LLC, as parties to the submitted settlement agreement, and potentially non-parties who might otherwise be affected by the agreement’s language.
What happened
In Fritz v. Manhattan Beer Distributors LLC, the parties filed letters asking whether provisions in their settlement agreement would be considered fair and reasonable. The agreement concerned claims relating to Fritz’s employment, including payment of wages or benefits.
The court treated the letters as a request to approve the submitted settlement agreement and release, rather than as a request for advice. It found no provision, including the three provisions identified by the parties, that justified rejecting the settlement.
Judge Schofield said one provision would be better edited to reflect that a contract cannot bind people who are not parties to it. The court ordered that the parties could withdraw their request for approval within one week of the order.
The detailed version
- Fritz v. Manhattan Beer Distributors LLC · No. 1:21-cv-04727
- Lorna Schofield
- Feb. 10, 2022
Background
The court had previously ordered the parties to file their settlement agreement and a letter addressing approval under the standards discussed in Cheeks v. Freeport Pancake House, Inc. and Wolinsky v. Scholastic, Inc. On February 8, 2022, the parties filed two letters asking whether three provisions in their settlement agreement would be considered fair and reasonable.
Court’s Analysis
The court stated that it does not issue advisory rulings. It therefore construed the parties’ letters as a request for approval of the settlement agreement and release as submitted. The court did not find any provision, including the three identified provisions, to be a basis for rejecting the settlement.
One disputed provision said, among other things, that the agreement could not be cited as an admission by Manhattan Beer Distributors LLC or used as evidence in another action, investigation, or proceeding, except for enforcing or implementing the agreement or proving its existence. The court said the provision, as drafted, was not a basis to deny approval, but preferred an edited version. The court explained that an agreement is a contract and cannot bind people who are not parties to it, regardless of what the agreement says. The court viewed the edited language as better able to avoid disputes or confusion involving non-parties.
Disposition
The court ordered that the parties could withdraw their request for approval of the settlement within one week of the order. The opinion states that the court found no basis to reject the settlement; it does not separately state that final approval was entered.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.