Williams v. Keyless LLC
- Rochon
- 1:22-cv-04440
- U.S. District Court · Southern District of New York
- 3
In Williams v. Keyless, Judge Rochon ordered the parties to submit their FLSA settlement for fairness review and warned about unacceptable confidentiality, release, and non-disparagement terms.
Ronald Williams and defendants Keyless LLC and N.Y. Residential Property Works LLC, whose proposed Fair Labor Standards Act settlement must be submitted for court review.
What happened
In Williams v. Keyless LLC, the court said a mediator reported that the parties had reached an agreement on all issues in Ronald Williams’s Fair Labor Standards Act overtime case.
The court explained that FLSA settlements, including proposed attorney’s fees, must be reviewed for fairness when the parties seek dismissal under Rule 41. It ordered the parties to submit the settlement agreement and a joint letter explaining the proposed settlement by May 20, 2024.
Judge Jennifer L. Rochon also warned that the court would not approve certain confidentiality, overly broad release, or non-disparagement provisions unless the parties provided case-specific justification. The order did not approve or reject the settlement.
The detailed version
- Williams v. Keyless LLC · No. 1:22-cv-04440
- Rochon
- May 6, 2024
Background
The action was brought under the Fair Labor Standards Act, a federal law governing wage and overtime requirements. The court-ordered mediator notified the court on April 25, 2024, that the parties had reached an agreement on all issues. The opinion does not state the settlement amount or provide the settlement’s terms.
Court’s analysis
The court explained that an employer violating the overtime-pay requirement may owe unpaid overtime compensation and an equal amount in liquidated damages. It also explained that, when parties settle FLSA claims and contemplate dismissal under Rule 41 of the Federal Rules of Civil Procedure, the court must review the settlement—including any proposed attorney’s fee award—to determine whether it is fair and reasonable.
Order
The court ordered the parties to submit the settlement agreement and a joint letter by May 20, 2024. The letter must explain the basis for the proposed settlement and why it should be approved as fair and reasonable if the parties contemplate Rule 41 dismissal. It must also address any incentive payment to the plaintiff and any proposed attorney’s fee award, with supporting documentation when appropriate.
The court advised that it would not approve a settlement containing a confidentiality provision without sufficient case-specific reasons overcoming the public’s common-law right of access to judicial documents. It also would not approve a release or waiver covering claims that had not accrued or claims unrelated to wage-and-hour matters without case-specific justification. Finally, it would not approve a clause barring the plaintiff from making negative statements about a defendant unless the clause included an exception for truthful statements about the plaintiff’s experience litigating the case, or the parties supplied case-specific justification for omitting that exception.
If the agreement contains any of those provisions, the parties must state whether they want the court to consider approving the agreement with the provisions removed. The court noted that it may approve or reject an FLSA settlement but may not modify the agreement itself. The opinion does not state that the court approved or rejected the settlement.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.