Nyamoti v. The Mount Sinai Hospital
- Valerie Caproni
- 1:21-cv-07926
- U.S. District Court · Southern District of New York
- 2
In Nyamoti v. The Mount Sinai Hospital, Judge Caproni required a narrower settlement release or explanation and adjourned the pretrial conference.
Enock Nyamoti, The Mount Sinai Hospital, and the parties’ proposed settlement.
What happened
In Nyamoti v. The Mount Sinai Hospital, Enock Nyamoti, who was representing himself, brought claims under the Fair Labor Standards Act and New York labor laws.
The parties submitted a proposed $250,000 settlement for court approval. It allocated $125,000 to backpay and $125,000 to damages, attorneys’ fees, and costs, but broadly released the hospital from all claims arising from the complaint, including claims unrelated to wage-and-hour issues.
Judge Valerie Caproni ordered the parties to submit a revised agreement with a narrower release by March 24, 2023, or have the hospital explain why the broad release should be approved. She also adjourned the scheduled pretrial conference indefinitely.
The detailed version
- Nyamoti v. The Mount Sinai Hospital · No. 1:21-cv-07926
- Valerie Caproni
- Mar. 15, 2023
Background
Enock Nyamoti, proceeding without a lawyer, filed an amended complaint alleging violations of the Fair Labor Standards Act (FLSA) and New York labor laws. On March 15, 2023, the parties submitted a proposed settlement agreement for the court’s approval.
Proposed Settlement
The proposed settlement totaled $250,000. It allocated $125,000 as backpay and $125,000 for damages, attorneys’ fees, and costs. The agreement also released The Mount Sinai Hospital from “any and all claims, liabilities or causes of action” arising from the allegations in the complaint, whether or not those claims related to wage-and-hour issues.
The court cited Second Circuit precedent stating that judicial approval of FLSA settlements is needed in part to protect plaintiffs from overbroad releases that could waive unrelated or unknown claims.
Ruling
Judge Valerie Caproni ordered that, by March 24, 2023, the parties must either submit a revised proposed settlement with a narrower release provision or have The Mount Sinai Hospital submit a letter explaining why the settlement should be approved despite its broad release. The order did not approve the settlement as submitted. The court also adjourned the March 17, 2023 pretrial conference indefinitely.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.