Qanouni v. D & H Ladies Apparel LLC
- Figueredo
- 1:18-cv-02763
- U.S. District Court · Southern District of New York
- 3
In Qanouni v. D&H Ladies Apparel, Judge Figueredo denied the settlement-approval motion without prejudice because the release was not mutual and was too broad.
The plaintiffs and defendants in the wage-and-hour action, whose proposed settlement was not approved in its submitted form.
What happened
Qanouni v. D&H Ladies Apparel LLC is a wage case brought under the Fair Labor Standards Act and New York Labor Law. The parties reached an agreement in principle and asked the court to approve their proposed settlement.
The court found two problems with the release in the agreement. It required the plaintiffs to release claims against the defendants without requiring the defendants to release the plaintiffs, and it covered many people and entities beyond the defendants themselves.
Judge Valerie Figueredo denied the parties’ motion for settlement approval without prejudice. The court said the parties could submit a revised agreement correcting the release, and stated that it would approve a revised agreement reflecting those changes as fair and reasonable.
The detailed version
- Qanouni v. D & H Ladies Apparel LLC · No. 1:18-cv-02763
- Figueredo
- Feb. 10, 2023
Background
The plaintiffs brought this action under the Fair Labor Standards Act and New York Labor Law. The parties consented to the jurisdiction of the magistrate judge under 28 U.S.C. § 636(c). After reaching an agreement in principle, they jointly asked the court to approve their proposed settlement. The parties also submitted a letter explaining why they believed the settlement was fair, reasonable, and adequate.
Court’s Analysis
The court reviewed the proposed settlement to determine whether it was a reasonable compromise of the claims. It found that the release provision was improper in two ways.
First, the release was not mutual. The agreement required the plaintiffs to release the defendants from wage-related and other claims, but the defendants did not release the plaintiffs from liability.
Second, the release was overbroad. It applied not only to the defendants but also to numerous other people and entities, including owners, employees, attorneys, affiliates, insurers, successors, representatives, heirs, and other related parties. The court concluded that the release needed to be limited and amended.
Disposition
The court denied the parties’ motion for settlement approval without prejudice to refiling a revised settlement agreement that corrected the release provision. The court stated that, after the parties submitted a revised agreement reflecting those changes, it would approve the settlement as fair and reasonable.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.