Rana v. Rani Mahal Fine Indian Cuisine, Inc.

Background

Mohammed Rana brought claims against Rani Mahal Fine Indian Cuisine, Inc. and Abdul Jalil under the Fair Labor Standards Act (FLSA) and New York Labor Law. On August 8, 2023, Rana filed a settlement agreement and a statement explaining its terms, as required for court review under the Second Circuit’s settlement-review rule.

Settlement Terms and Court’s Review

The total settlement amount was $75,000. The agreement attributed $24,898.01 to Rana’s FLSA claims and another $24,898.01 to his non-wage-and-hour claims. Rana stated that his best possible recovery, assuming all disputed facts were resolved in his favor, would be $179,190.20, and that the $49,796.02 net settlement amount was reasonable.

The court identified a genuine dispute about whether Rana was exempt from the FLSA during his employment and about the number of overtime hours he worked. It also noted that all parties were represented by counsel, the settlement was reached with help from a neutral mediator, and the parties wanted to avoid the cost and uncertainty of continued litigation. Rana no longer worked for the defendants. The release covered only employment-related claims accruing before Rana signed the agreement, and the agreement contained no confidentiality or non-disparagement provision.

The court found that the agreement was fair and reasonable and resulted from arm’s-length negotiations rather than fraud or collusion. It also found reasonable the attorney’s fees, which were one-third of the gross settlement amount, plus reimbursement of costs.

Disposition

The court approved the parties’ settlement agreement. It directed the Clerk to close the case. The opinion resolved the settlement-approval issue and did not determine the underlying FLSA or New York Labor Law claims on their merits.