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S.D.N.Y.Procedural orderFiled Oct. 28, 2022

Robles Sanchez v. Payam Inc.

Judge
Valerie Caproni
Docket
1:21-cv-09628
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureEmployment
In one sentence

In Robles Sanchez v. Payam Inc., Judge Caproni declined to approve the proposed wage-and-hour settlement because its release was too broad.

Who this affects

The proposed settlement parties—Carlos Agostin Robles Sanchez, Payam Inc., Paprika II LLC, and Paprika LLC—were affected because the settlement was not approved and the parties were given an opportunity to submit a narrower agreement.

What happened

In Robles Sanchez v. Payam Inc., Carlos Agostin Robles Sanchez and Payam Inc., Paprika II LLC, and Paprika LLC submitted a proposed settlement for court approval.

The court had found the requested attorney fee and settlement amount reasonable, but rejected the first agreement because its release was too broad. The parties then submitted a revised agreement limiting some of the release language.

The revised agreement still appeared to cover claims beyond the wage-and-hour case, so Judge Valerie Caproni did not approve it as fair and reasonable. The parties were allowed to submit another agreement releasing only wage-and-hour claims by November 4, 2022.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Robles Sanchez v. Payam Inc. · No. 1:21-cv-09628
Judge
Valerie Caproni
Date
Oct. 28, 2022

Background

The parties submitted a proposed settlement agreement for the Court’s approval under Cheeks v. Freeport Pancake House, Inc. The Court had previously found that the requested attorney fee and settlement amount were reasonable, but concluded that the agreement was not fair or reasonable because its release of claims was too broad.

The Court allowed the parties to submit a revised agreement containing only a release of wage-and-hour claims. On October 26, 2022, the parties submitted a revised agreement. Paragraph 1(a) stated that, if any complaint, appeal, lawsuit, charge, claim, or proceeding other than this action had been filed or was later filed by or on behalf of Robles Sanchez, he would take steps to dismiss or withdraw it with prejudice and would not obtain or accept recovery or relief from it.

Ruling

The Court interpreted Paragraph 1(a) as extending to claims beyond those related to the wage-and-hour action. It therefore ordered that the proposed settlement agreement was not approved as fair and reasonable because of the breadth of its release. Judge Valerie Caproni stated that the Court would be prepared to approve a settlement releasing only wage-and-hour-law claims and permitted the parties to submit a consistent revised agreement no later than November 4, 2022.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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