Jdahim v. A1 Accessible Transportation, LLC
- Paul Engelmayer
- 1:23-cv-06509
- U.S. District Court · Southern District of New York
- 2
In Jdahim v. A1 Accessible Transportation, LLC, Judge Engelmayer declined FLSA settlement review because plaintiffs accepted Rule 68 offers of judgment.
Zakaria Jdahim, Abdelhamid Mohammed Islam Ahmed, and the defendants in this FLSA and New York Labor Law action.
What happened
Jdahim v. A1 Accessible Transportation, LLC involved claims under the Fair Labor Standards Act and New York Labor Law. The parties submitted a settlement agreement to the court.
Zakaria Jdahim and Abdelhamid Mohammed Islam Ahmed accepted the defendants’ offers of judgment under Federal Rule of Civil Procedure 68. That rule provides a procedure for resolving a case through an accepted formal offer of judgment.
Judge Engelmayer ruled that the court would not conduct the usual fairness review of the Fair Labor Standards Act settlement because the plaintiffs accepted Rule 68 offers. He stated that a separate order would approve the parties’ proposed judgment.
The detailed version
- Jdahim v. A1 Accessible Transportation, LLC · No. 1:23-cv-06509
- Paul Engelmayer
- Mar. 14, 2024
Background
The case involves claims under the Fair Labor Standards Act (FLSA) and the New York Labor Law. On March 7, 2024, the parties submitted a settlement agreement. Zakaria Jdahim and Abdelhamid Mohammed Islam Ahmed accepted offers of judgment from the defendants under Federal Rule of Civil Procedure 68.
Issue
The court considered whether it had to review the parties’ FLSA settlement for fairness. Generally, private settlements of FLSA claims that end the claims permanently require approval by a district court or the Department of Labor. The court relied on a Second Circuit decision holding that court approval is not required when an FLSA claim is resolved through an accepted Rule 68(a) offer of judgment. Rule 68(a) requires the clerk to enter judgment after a qualifying offer is accepted.
Ruling
The court stated that it would not conduct the usual FLSA settlement review because the plaintiffs had accepted Rule 68 offers of judgment. The court also stated that it would approve the parties’ proposed judgment by separate order. This opinion itself does not include the separate judgment order.
Disposition
The opinion directs that no fairness review will be conducted and states that a separate order will approve the proposed judgment. It does not state that the separate judgment had already been entered in this opinion.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.