Ramales v. Peace Food Cafe, Inc.

Background

Marcos Ramales brought claims under the Fair Labor Standards Act against Peace Food Cafe, Inc. and other defendants. After mediation, the parties reached a settlement covering all issues.

On February 3, 2022, the court directed the parties to submit the settlement agreement and explain why the settlement—including any attorney’s fees and costs—was fair, reasonable, and adequate. On February 15, 2022, the parties consented to referral of the matter to Magistrate Judge Stewart D. Aaron for disposition under 28 U.S.C. § 636(c). The parties submitted their proposed settlement and related papers on March 15, 2022.

Settlement and Fees

The court reviewed the proposed settlement and found it fair and reasonable in light of the nature and scope of Ramales’s individual claims and the risks and expenses of further litigation.

Ramales sought approval of $12,666.67 in attorney’s fees and costs, which represented one-third of the total settlement amount. The court noted that courts in the circuit typically approve attorney’s fees equal to one-third of the total recovery and regularly award multipliers of two to six times the lodestar, a calculation used to assess fees based on counsel’s time and hourly rates. The court found the requested fees fair and reasonable but expressly made no finding about the reasonableness of counsel’s hourly rates.

Ruling

Judge Stewart D. Aaron approved the settlement. The action was dismissed with prejudice and without costs except as stated in the settlement agreement. The court retained jurisdiction to enforce the settlement agreement and requested that the Clerk of Court close the case.