Castillo v. MG Deli Grocery, Corp.

Background

Radhames Castillo sued MG Deli Grocery, Corp., and other defendants individually and on behalf of others similarly situated under the Fair Labor Standards Act, a federal wage-and-hour law. The court was notified that the parties had reached a settlement. The opinion does not state the settlement amount, its other terms, or whether the court ultimately approved it.

Settlement-filing requirements

The court stated that the parties could not dismiss the action with prejudice based on the settlement unless either the court or the Department of Labor approved the settlement. Within thirty days of the order, the parties were required to file a letter motion and the settlement agreement on the public docket. The court directed the letter motion to explain why the proposed settlement was fair and reasonable.

The required explanation had to address: Castillo’s possible recovery; the burdens and expenses the settlement would avoid; the seriousness of the parties’ litigation risks; whether experienced counsel negotiated the agreement at arm’s length; and the possibility of fraud or collusion. The filing also had to discuss whether there was a genuine dispute about the number of hours worked or the compensation due, and how much Castillo’s attorney would seek in fees. The court stated that, absent special circumstances, it would not approve a settlement filed under seal or in redacted form.

Ruling and effect

The court ordered the parties to file the required letter or a stipulation by June 17, 2022. It postponed all other filing deadlines and conference dates without setting new dates. The order required further settlement review but did not approve or reject the settlement.