Johnson v. M.A.C. Cosmetics, Inc.
- Vernon Broderick
- 1:18-cv-09157
- U.S. District Court · Southern District of New York
- 5
Johnson v. M.A.C. Cosmetics, Inc.: Judge Broderick approved a revised wage-and-hour settlement after requiring a narrower claims release.
The plaintiffs and defendants in the FLSA action are affected. The approved settlement resolves the action, but the opinion does not state the settlement amount or other payment terms.
What happened
In Johnson v. M.A.C. Cosmetics, Inc., the parties asked the U.S. District Court for the Southern District of New York to approve their settlement of claims under the Fair Labor Standards Act, a federal wage-and-hour law. The court had previously denied approval because the agreement released claims too broadly.
The revised agreement limited the release to the plaintiffs’ wage-and-hour claims and stated that the plaintiffs released no other claims. After reviewing the agreement, supporting materials, and counsel’s description of their work, the court found the settlement fair and reasonable.
Judge Vernon S. Broderick granted the motion to approve the agreement. He directed the Clerk of Court to close the open motion and terminate the action.
The detailed version
- Johnson v. M.A.C. Cosmetics, Inc. · No. 1:18-cv-09157
- Vernon Broderick
- May 24, 2022
Background
The plaintiffs and defendants reached a settlement in this Fair Labor Standards Act (FLSA) case. The parties first sought approval in March 2021. On November 12, 2021, the court denied approval because the settlement contained an overly broad release of claims, which made the agreement unfair and unreasonable. The parties later submitted a revised settlement agreement and asked the court to approve it.
Legal standard
The court explained that parties generally may not privately settle FLSA claims without approval from the district court or the Department of Labor. When court approval is required, the court must determine whether the settlement is fair and reasonable. The court considers the total circumstances, including the plaintiffs’ possible recovery, the burdens and expenses of continued litigation, the risks faced by the parties, whether experienced counsel negotiated at arm’s length, and the possibility of fraud or collusion. If the settlement includes attorneys’ fees and costs, the court also evaluates whether those amounts are reasonable and supported by adequate documentation.
Court’s analysis
The court reviewed the revised settlement agreement, a supporting declaration, evidence, and plaintiffs’ counsel’s description of the work performed. It incorporated its earlier findings that the prior agreement was proper except for the release provision. The revised agreement retained the previously acceptable provisions and changed the release.
The revised agreement released defendants from wage-and-hour claims the plaintiffs had or might have, while stating that the plaintiffs did not release claims outside the wage-and-hour claims described in the agreement. The court found that this narrower release was fair and reasonable because it was limited to wage-and-hour claims.
Disposition
The court found the revised settlement agreement fair and reasonable and granted the motion to approve the parties’ agreement. The Clerk of Court was directed to close the open motion at docket number 68 and terminate the action.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.