Morales Campos v. Up Thai Corp.

Background

The plaintiffs brought this wage-and-hour case under the Fair Labor Standards Act against Up Thai Corp., doing business as Tung Thong 181, and Jirapat Puttana Wong. The parties consented to the jurisdiction of Magistrate Judge Valerie Figueredo to review their proposed settlement. They first submitted a settlement for approval, but the court requested additional information about each plaintiff’s estimated damages, each plaintiff’s settlement payment, and the reasonableness of the proposed $32,980 in attorneys’ fees.

Revised Settlement Submission

The parties later submitted a revised settlement agreement. Plaintiffs’ counsel reduced the requested attorneys’ fees to $8,720 and provided billing records showing the rates charged, hours worked, and tasks performed. The court found that fee request reasonable because it was less than one-third of the settlement amount and substantially lower than the earlier request.

The revised submission did not, however, state each plaintiff’s estimated total damages or the amount each plaintiff would receive under the settlement. The submission included a damages chart, but the parties explained that it reflected the plaintiffs’ original damages demand, which the defendants disputed. The chart did not show each plaintiff’s ultimate recovery under the settlement.

Ruling

The court stated that it could not approve the proposed settlement without information showing each plaintiff’s possible damages and settlement payment. Judge Figueredo therefore did not approve the settlement at that time and directed the parties to submit a joint letter addressing this issue by May 16, 2024. The order did not make a final determination about the fairness of the settlement.