Hudis v. Situ Group, Inc.

District Court, S.D. New York·Decided October 24, 2022·No. 1:21-cv-07960·Unknown

Opinion

UNITED STATES DISTRICT COURT DOCUMENT SOUINERN DISTRICT OF NEW YORK. □□□ TRONICALLY FILED Plaintiffs. DATE FILED: _10/24/2022 -against- 21 Civ. 7960 (AT) SITU GROUP, INC. and KIEFER LE MOIGNE, ORDER Defendants. ANALISA TORRES, District Judge: Plaintiffs Jordan Hudis and Thomas Ritchie bring this action against Defendants Situ Group, Inc., and Kiefer Le Moigne, claiming, inter alia, unpaid overtime wages under the Fair Labor Standards Act (“FLSA”), 29 U.S.C. § 201 ef seq., and unpaid wages, illegally withheld wages, and wage notice and statement violations under the New York Labor Law (“NYLL”) § 190 et seg. See generally Compl., ECF No. 1. Having reached a settlement (the “Settlement”), ECF No. 37-2, the parties sought the Court’s approval of their proposed agreement. See Letter, ECF No. 37. After seeking approval, the parties filed an amended settlement (the “Amendment”), which pins the payment date to the approval of the settlement and incorporates all remaining provisions of the Settlement. ECF No. 41-1; see also ECF No. 41. Accordingly, the Court shall review the Settlement and the Amendment. For the reasons stated below, the motion is DENIED without prejudice to renewal. DISCUSSION L Legal Standard The FLSA was enacted “to correct and as rapidly as practicable to eliminate” certain “labor conditions detrimental to the maintenance of the minimum standard of living necessary for health, efficiency, and general well-being of workers.” 29 U.S.C. § 202(a}1b). Significantly,

“[r]ecognizing that there are often great inequalities in bargaining power between employers and employees, Congress made the FLSA’s provisions mandatory; thus, the provisions are not subject to negotiation or bargaining between employers and employees.” Lynn’s Food Stores, Inc. v. U.S. Dep’t of Labor, 679 F.2d 1350, 1352 (11th Cir. 1982) (citing Brooklyn Savs. Bank v. O’Neil, 324 U.S. 697, 706 (1945)).

In accordance with the FLSA’s mandatory provisions, an employer cannot settle claims of unfair wages without approval of the settlement from the Department of Labor or a United States district court. See Wolinsky v. Scholastic Inc., 900 F. Supp. 2d 332, 335 (S.D.N.Y. 2012). Where, as here, the parties seek approval from the district court, they must establish the settlement is “fair and reasonable.” Persaud v. D & H Ladies Apparel LLC, No. 16 Civ. 5994, 2017 WL 1944154, at *1 (S.D.N.Y. May 8, 2017) (citation omitted). To determine whether a settlement is fair and reasonable, courts consider: the totality of circumstances, including but not limited to the following factors: (1) the plaintiff’s range of possible recovery; (2) the extent to which “the settlement will enable the parties to avoid anticipated burdens and expenses in establishing their respective claims and defenses”; (3) the seriousness of the litigation risks faced by the parties; (4) whether “the settlement agreement is the product of arm’s- length bargaining between experienced counsel”; and (5) the possibility of fraud or collusion.

Wolinsky, 900 F. Supp. 2d at 335 (quoting Medley v. Am. Cancer Soc’y, No. 10 Civ. 3214, 2010 WL 3000028, at *1 (S.D.N.Y. July 23, 2010)). In addition, courts should not approve agreements that contain “highly restrictive confidentiality provisions” and “overbroad” releases of claims. Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199, 206 (2d Cir. 2015) (citation omitted). Where the proposed settlement provides for payment of attorney’s fees, the Court must separately assess the reasonableness of the fee award. Lliguichuzhca v. Cinema 60, LLC, 948 F. Supp. 2d 362, 366 (S.D.N.Y. 2013) (citation omitted). “In an individual FLSA action where the 2 parties settled on the fee through negotiation, there is ‘a greater range of reasonableness for approving attorney’s fees.’” Wolinsky, 900 F. Supp. 2d at 336 (quoting Misiewicz v. D’Onofrio Gen. Contractors Corp., No. 08 Civ. 4377, 2010 WL 2545439, at *5 (E.D.N.Y. May 17, 2010)). Still, “counsel must submit evidence providing a factual basis for the award,” including “contemporaneous billing records documenting, for each attorney, the date, the hours expended,

and the nature of the work done.” Id. II. Analysis The Settlement and Amendment provide Plaintiffs with a recovery of $217,500, with Ritchie receiving approximately $77,720, Hudis receiving approximately $67,280, and their attorneys receiving the remainder. Amendment ¶ 1; see also Settlement ¶ 3. During mediation, Plaintiffs estimated their best-case recovery to be $897,292.29, meaning that the proposed settlement offer is roughly 24.24% of the possible recovery under Plaintiffs’ best-case scenario for damages. Letter at 2–3; ECF No. 37-1. The parties note that the Settlement recovery represents “more than 95% of [Plaintiffs’] respective unpaid salaries for the time that the Plaintiffs worked

for Defendants.” Letter at 3. The parties acknowledge that any litigation would likely have been protracted, likely ending in a trial, and the settlement allows the parties to “preserve[] substantial additional resources” that this litigation would have required. Id. at 4. And, Plaintiffs have concerns about ability to recover damages should they have prevailed in the lawsuit—they note that the “Settlement accounts for the potential difficulties in enforcing a judgment.” Id.; see Lliguichuzhca, 948 F. Supp. 2d at 365 (“[P]otential difficulty in collecting damages militates in favor of finding a settlement reasonable.”). In addition, the parties state that the Settlement was the product of a “day-long mediation” conducted by the District’s mediation program. Letter at 3–4. Plaintiffs were represented by experienced counsel throughout the mediation. Id. at 4. 3 However, the parties do not explicitly state the risks faced by the parties in the litigation, beyond Plaintiffs’ concerns about recoverability, nor do they state that there was no fraud or collusion in the negotiation of the Settlement and Amendment beyond the heading of Section V. See generally Letter. The Court cannot find, therefore, that the Wolinsky factors are met. In addition, the Settlement contains a liability release, which the Court finds improper.

Settlement ¶ 7. The Settlement releases from liability numerous entities beyond Defendants, including “officers, boards, directors, staff, employees, attorneys, insurers, members, managers, principals, general and limited partners, agents, lenders, and assigns.” Id. Although the release clause is limited only to claims “arising from, relating to, or in connection with the subject matter of the Lawsuit, the commencement or prosecution or defense of the Lawsuit, the facts giving rise to, as well as the claims and demands that were or could have been asserted in, the Lawsuit,” id., “when combined with the broad definition of ‘[r]eleasees,’ the release—read literally—would have the . . . effect of releasing any wage and hour claims that [Plaintiffs] had against a wide range of unidentified individuals and business[es] only tenuously affiliated with [Defendants].” Lara v.

Air Sea Land Shipping & Moving Inc., No. 19 Civ. 8486, 2019 WL 6117588, at *2 (S.D.N.Y. Nov. 18, 2019). The Court cannot, therefore, conclude that the Settlement’s release clause is “fair and reasonable” under Cheeks, and, accordingly, shall not approve the Settlement.

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Hudis v. Situ Group, Inc., (S.D.N.Y. 2022).

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