Brown v. Memorial Sloan-Kettering Cancer Center

Background

Claudine Brown brought claims under the Fair Labor Standards Act against Memorial Sloan-Kettering Cancer Center. On September 4, 2023, the parties reported that they had reached a settlement in principle on all issues. The court then directed them to submit the settlement agreement and explain why it was fair and reasonable. The parties submitted the proposed agreement and supporting papers on October 19, 2023.

Court’s Analysis

The court found the settlement fair and reasonable based on the nature and scope of Brown’s individual claims and the risks and expenses of continuing the litigation. The agreement included a mutual general release, a provision that courts generally disfavor. The court found the release acceptable because Brown no longer worked for the defendant and had been represented by experienced counsel.

Brown also sought approval of $17,339 in attorney’s fees, described as one-third of the total settlement amount, and $482 in costs. The court found the requested fees fair and reasonable because courts in the district typically approve fees equal to one-third of the total recovery. The court stated that it was not making any findings about the reasonableness of counsel’s hourly rates.

Ruling

Judge Stewart D. Aaron approved the settlement. The action was dismissed with prejudice and without costs except as stated in the settlement agreement. The court retained jurisdiction to enforce the settlement agreement and directed the clerk to close the case.