Crawford v. Leeding Builders Group, LLC
- Analisa Torres
- 1:23-cv-07290
- U.S. District Court · Southern District of New York
- 2
In Crawford v. Leeding, Judge Torres kept the FLSA case open, refusing to approve dismissal while arbitration remained unresolved.
The ruling affects the plaintiffs and defendants in the FLSA overtime case: the proposed dismissal was not approved, the case remains open, and litigation deadlines and conferences are paused while arbitration proceeds.
What happened
Crawford v. Leeding Builders Group, LLC is a wage case in which the plaintiffs alleged that the defendants failed to pay overtime under the Fair Labor Standards Act. The plaintiffs filed a notice seeking to end the case without prejudice after saying they were pursuing their claims in arbitration.
The court had previously refused to approve the dismissal because settlements of Fair Labor Standards Act claims generally require court or Department of Labor review for fairness. The plaintiffs argued that this review was unnecessary because they were pursuing arbitration, but the court rejected that argument.
Judge Analisa Torres refused to approve the dismissal because arbitration had not yet resolved the claims and the parties might still reach a private settlement. The case remains open, but deadlines are stayed, conferences are canceled, and the plaintiffs must provide a status update by April 15, 2024.
The detailed version
- Crawford v. Leeding Builders Group, LLC · No. 1:23-cv-07290
- Analisa Torres
- Feb. 8, 2024
Background
Algi Crawford, Xavier Harrison, and Keveen Goris brought this putative collective and class action against Leeding Builders Group, LLC and AECOM. The complaint alleged, among other things, that the defendants failed to pay overtime wages in violation of the Fair Labor Standards Act (FLSA).
On February 5, 2024, the plaintiffs submitted a notice of voluntary dismissal without prejudice under Federal Rule of Civil Procedure 41(a)(1)(A)(i). The court had previously refused to approve the proposed dismissal, explaining that parties cannot use voluntary dismissal to avoid the court’s obligation to review an FLSA settlement for fairness. FLSA settlements require approval by the district court or the Department of Labor.
Parties’ Position
In response, the plaintiffs’ counsel argued that dismissal was proper because the plaintiffs were pursuing their claims in arbitration. Counsel stated that the plaintiffs had served the defendants with a notice of arbitration demand at the same time they filed the notice of voluntary dismissal.
Court’s Analysis
The court recognized that FLSA claims can be arbitrated. It nevertheless concluded that an FLSA settlement is not exempt from judicial fairness review merely because the settlement was reached while the case was stayed pending arbitration. The court stated that district courts within the circuit had uniformly required fairness review of settlements reached in that circumstance.
The court also noted that the claims had not yet been adjudicated through arbitration. Therefore, the parties might still reach a private settlement outside arbitration, making it inappropriate to approve the proposed dismissal at that time.
Ruling and Case Status
Judge Analisa Torres refused to approve the stipulation of dismissal, and the case remains open. The court stayed all deadlines and vacated all conferences pending the outcome of arbitration. The plaintiffs must file an update on the status of the arbitration and adjudication of their claims by April 15, 2024. The opinion did not decide whether the plaintiffs were entitled to overtime wages or otherwise resolve the underlying FLSA claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.