Lee v. Grove Group Advisors LLC

Background

Brian Lee sued Grove Group Advisors LLC, Grove Group Management, Inc., and Kevin Shin under the Fair Labor Standards Act, a federal wage law, and New York labor law. The parties reached a settlement, and the court approved it as fair and reasonable on December 28, 2021. The written agreement required Defendants to pay $14,990 in full by January 11, 2021. Lee stated that Defendants had not paid any of the settlement funds.

Lee moved to enforce the executed settlement agreement. The court gave Defendants multiple opportunities to respond, including an order asking why the motion should not be treated as unopposed. Defendants filed no response, and the court treated the motion as fully briefed and unopposed.

Legal standard

The court explained that it may summarily enforce a settlement reached in a case before it. A settlement is a contract governed by general contract principles. Under the standard discussed by the court, an enforceable agreement requires an offer, acceptance, consideration, mutual agreement, and an intent to be bound. A settlement may be set aside only for good cause, such as fraud, collusion, mistake, pressure that overcomes free choice, lack of capacity, unconscionability, violation of public policy, or ambiguity showing that the parties never reached agreement.

Court’s decision

The court found that the parties had a written agreement signed by Lee and by Shin in his capacity as chief executive officer of the Grove entities. The court had already approved the agreement. Defendants did not dispute that they signed it and did not claim that fraud, mistake, or pressure caused them to enter it. Considering the circumstances, the court found the agreement enforceable and granted Lee’s motion to enforce it.

The court also calculated interest under New York law at 9% per year. It calculated $3,034.55 in interest on the $14,990 principal from January 11, 2021, when payment was due, through April 12, 2023, when Lee filed the enforcement motion. The court ordered Lee to recover $14,990 plus $3,034.55 in interest, for a total of $18,024.55, from Grove Group Advisors LLC, Grove Group Management, Inc., and Kevin Shin, jointly and severally.