Goudarzi v. Seasons A Floral Design Studio
- Paul Engelmayer
- 1:22-cv-02808
- U.S. District Court · Southern District of New York
- 3
In Goudarzi v. Seasons A Floral Design Studio, Judge Engelmayer declined to approve the proposed wage settlement and required more information.
Hamed Goudarzi, Seasons A Floral Design Studio, Luis Daniel Munoz, and plaintiff’s counsel were affected by the court’s refusal to approve the proposed settlement and its required next steps.
What happened
Hamed Goudarzi and the defendants submitted a proposed settlement in a case under the Fair Labor Standards Act and New York Labor Law. The court reviewed the agreement but said it lacked enough information to evaluate it.
The court needed information about the strength of the dispute, the amount Goudarzi could receive if he won at trial, the amount allocated to attorney fees, and records supporting those fees. It therefore did not approve the proposed settlement at that stage.
Judge Engelmayer gave the parties three choices: submit a revised agreement and supporting information by January 17, 2023; state that they were abandoning the settlement and would continue litigating; or stipulate to dismiss the case without prejudice, which would not require court approval.
The detailed version
- Goudarzi v. Seasons A Floral Design Studio · No. 1:22-cv-02808
- Paul Engelmayer
- Dec. 9, 2022
Background
Hamed Goudarzi brought an action under the Fair Labor Standards Act (FLSA) and New York Labor Law against Seasons A Floral Design Studio and Luis Daniel Munoz. On December 8, 2022, the parties submitted a proposed settlement agreement.
Court’s analysis
The court explained that private settlements of FLSA claims that end those claims with prejudice require approval by the district court or the Department of Labor. The court must determine whether the settlement is fair and reasonable, and it must separately assess whether the proposed attorney fees are reasonable.
The parties’ submission did not provide enough information for those assessments. Specifically, plaintiff’s counsel did not provide sufficient information about the genuine basis for the dispute; information allowing the court to evaluate whether the settlement amount was fair and reasonable compared with what Goudarzi could recover at trial; the part of the settlement allocated to attorney fees; or documentation supporting the requested fees, including contemporaneous time records and hourly-rate information for all attorneys and staff who worked on the case.
Ruling and next steps
Judge Engelmayer declined to approve the agreement at that stage. The parties could file a revised agreement and a joint letter addressing the court’s concerns by January 17, 2023; file a joint letter stating that they intended to abandon the settlement and continue litigating; or stipulate to dismissal without prejudice. The court stated that a settlement resulting in dismissal without prejudice does not require court approval.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.