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S.D.N.Y.Procedural orderFiled Mar. 18, 2024

Montero v. Primo Home Services Installation Inc.

Judge
Ho
Docket
1:23-cv-07340
Court
U.S. District Court · Southern District of New York
Pages
1
FlsaCivil Procedure
In one sentence

Montero v. Primo Home Services, Judge Ho ordered materials for court review of the parties’ settled Fair Labor Standards Act claims.

Who this affects

The parties to the FLSA case, including Bryan Montero and Primo Home Services Installation, Inc., and the court’s review of their proposed settlement.

What happened

In Montero v. Primo Home Services Installation Inc., the parties told the Southern District of New York that they had settled all issues after mediation through the court’s Mediation Program.

The court explained that, in the Second Circuit, parties generally cannot privately settle Fair Labor Standards Act claims through a dismissal with prejudice unless the court or the Department of Labor approves the settlement.

Judge Dale E. Ho ordered the parties to file materials for settlement approval by April 19, 2024. The order did not itself approve the settlement.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Montero v. Primo Home Services Installation Inc. · No. 1:23-cv-07340
Judge
Ho
Date
Mar. 18, 2024

Background

The parties informed the court that they had reached a settlement resolving all issues after mediation through the Southern District of New York’s Mediation Program. The opinion identifies the dispute as involving claims under the Fair Labor Standards Act (FLSA).

Settlement-Approval Requirement

The court stated that, in the Second Circuit, parties cannot privately settle FLSA claims through a stipulated dismissal with prejudice under Federal Rule of Civil Procedure 41 unless the district court or the Department of Labor approves the settlement. The court cited Second Circuit decisions describing factors courts use to evaluate whether a proposed settlement and attorneys’ fees are fair and reasonable.

Order

Judge Dale E. Ho ordered the parties to file materials seeking approval under the cited settlement-review standard by April 19, 2024. The opinion does not state that the court approved or rejected the settlement.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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