Laurent v. PricewaterhouseCoopers LLP

Background

The case concerned retirement-plan benefits. The court had previously granted preliminary approval of a settlement and approved the proposed mailed and published notices. The certified class included people who accrued benefits after June 30, 1994, held a cash-balance account under one of the specified Price Waterhouse or PricewaterhouseCoopers retirement plans, and received—or whose alternate payees, beneficiaries, or estates received—a lump-sum payment under the plan between March 23, 2000, and August 17, 2006, before the participant reached age 65.

The court held a fairness hearing on January 27, 2023, after providing notice to the class. No class member submitted a timely objection, and no objections were presented at the hearing. The court stated that the case had included two partial summary judgments in the class’s favor and two successful appeals, but it also stated that the case had previously been dismissed in its entirety with prejudice in 2017.

Rulings

The court approved the settlement agreement and its allocation plan as fair, reasonable, adequate, and in the best interests of the class under Federal Rule of Civil Procedure 23(e). The class was a non-opt-out class, so class members could not opt out of the settlement. The court found that the mailed and published notices were the best practicable notice under the circumstances and complied with Rule 23 and constitutional due-process requirements. It also found that the notice required by the Class Action Fairness Act complied with that statute.

The court approved settlement-administration costs of $125,000. It approved Class Counsel’s requested attorneys’ fee award of one-third of the total settlement amount, finding that the relevant factors supported the award. As a cross-check, the court found that the requested fee produced an implied multiplier of 4.65 based on counsel’s reported lodestar. The court also approved reimbursement of $489,484.38 in documented litigation expenses and costs, and awarded Timothy Laurent $50,000 and Smeeta Sharon $40,000 as class-representative service awards.

Effect of the Judgment

As of the settlement’s effective date, the released claims were released and discharged. The court barred the releasors from bringing or pursuing actions concerning those claims against released parties in any court or other forum. The judgment was not an admission of fault or liability and was not a finding that the claims or defenses were valid or invalid. Except as provided in the settlement and judgment, the court stated that the plaintiffs and class members would take nothing, and it dismissed their claims against the Plan with prejudice and without costs.

The court retained jurisdiction to implement, interpret, and enforce the settlement and judgment. If the settlement did not become final under its terms, the judgment would become void and be vacated retroactively, and the litigation would proceed as described in the agreement. The court entered a final and appealable judgment, directed the clerk to close the motion at ECF No. 301, and marked the case closed.