Santana v. TSJL Realty Corp.

Background

Dario Santana brought an action for damages under the Fair Labor Standards Act (FLSA), a federal wage-and-hour law, and the New York Labor Law against TSJL Realty Corp. and other defendants. The parties submitted a fully executed settlement agreement, and Santana asked the court to approve it.

Settlement review

The court explained that a federal court must review a settlement in an FLSA case to determine whether it is fair and reasonable and resulted from arm’s-length negotiation rather than employer overreaching. The court reviewed the settlement agreement and the parties’ letter. It considered, among other things, prior proceedings, the risks and costs of continuing the case, the possible range of recovery, the bargaining process, attorney’s fees, and the possibility of fraud or collusion.

The court noted that the agreement contained no confidentiality restrictions or non-disparagement provisions, that its release was tailored to the facts underlying Santana’s claims, and that the attorney’s fees fell within a fair and reasonable range.

Ruling

Judge Robert W. Lehrburger found the settlement agreement fair and reasonable and approved it. Because the case was resolved by settlement, the court dismissed and discontinued it in its entirety, with prejudice, without costs or fees to any party except as provided in the settlement agreement. The court directed the clerk to terminate all motions and deadlines and close the case.