Sanchez v. 2050 Valentine Avenue LLC

Background

The court stated that the parties had reached a settlement in this Fair Labor Standards Act case. The opinion does not describe the underlying wage claims or the proposed settlement's terms.

Settlement-approval requirement

The court ordered that the action could not be dismissed with prejudice based on the settlement unless either the court or the Department of Labor approved the settlement. If the parties sought dismissal with prejudice, they were required to do one of two things by April 1, 2022: file a joint letter motion asking the court to approve the settlement agreement, along with the agreement itself, or provide documentation showing approval by the Department of Labor.

The court said the letter motion had to explain why the proposed settlement was fair and reasonable. It identified factors the filing should address, including the plaintiff's possible recovery, the burdens and expenses the settlement would avoid, the litigation risks, whether experienced counsel negotiated at arm's length, and the possibility of fraud or collusion. The filing also had to address whether there was a genuine dispute about the number of hours worked or the compensation owed, and how much the plaintiff's attorney would seek in fees.

Attorney fees and settlement terms

Any request for attorney fees had to include contemporaneous billing records identifying, for each attorney, the date, hours worked, and nature of the work. The court also stated that, absent special circumstances, it would not approve a settlement filed under seal or in redacted form. Without compelling circumstances, it would not approve agreements containing broad nondisclosure provisions or releases of claims unrelated to Fair Labor Standards Act issues.

Disposition

The court did not approve the settlement or dismiss the action in this order. It stated that any pending motions were moot and vacated all conferences. Judge Analisa Torres issued the order.