Katelyn Anderson, on behalf of herself and similarly situated employees v. Vitac Corporation

CourtDistrict Court, D. Colorado
DecidedJanuary 22, 2026
Docket1:25-cv-00329
StatusUnknown

This text of Katelyn Anderson, on behalf of herself and similarly situated employees v. Vitac Corporation (Katelyn Anderson, on behalf of herself and similarly situated employees v. Vitac Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Katelyn Anderson, on behalf of herself and similarly situated employees v. Vitac Corporation, (D. Colo. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Philip A. Brimmer

Civil Action No. 25-cv-00329-PAB-NRN

KATELYN ANDERSON, on behalf of herself and similarly situated employees,

Plaintiff,

v.

VITAC CORPORATION,

Defendant.

ORDER

This matter is before the Court on the Joint Motion for Preliminary Approval of Class Action Settlement [Docket No. 74]. The Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331. I. BACKGROUND On January 31, 2025, plaintiff Katelyn Anderson filed her complaint on behalf of herself and all others similarly situated against defendant Vitac Corporation. Docket No. 1. Ms. Anderson was employed by defendant from October 2017 to November 2024 to create closed captions for defendant’s media clients. Id. at 3, ¶ 15. Defendant hired employees who are paid hourly. Id., ¶ 16. The complaint alleges that defendant required its employees to perform “prep time,” id., where they were required to clock-in and perform “preparation tasks,” such as connecting to customers’ facilities, conducting research, and conducting quality assurance, before the scheduled start of their shifts. Id. at 3, 4, ¶¶ 17, 21. The complaint alleges that Ms. Anderson and similarly situated employees recorded their prep time, but were not paid for that time. Id. at 3-4, ¶¶ 19, 24. Ms. Anderson seeks to represent a collective pursuant to the Fair Labor Standards Act (the “FLSA”), 29 U.S.C. § 216(b), and a class pursuant to Fed. R. Civ. P. 23. See id. at 4-7. On behalf of the collective, Ms. Anderson asserts a claim for

violation of the FLSA for unpaid wages. See id. at 7-8. On behalf of the class, Ms. Anderson asserts claims for violation of the Colorado Wage Act and for unjust enrichment. See id. at 8-9. II. HYBRID CLASS ACTIONS Ms. Anderson seeks to certify a hybrid class action. See Docket No. 1 at 2-3, ¶¶ 9-10. Hybrid class actions involve both a Rule 23 class action and FLSA collective actions. Pliego v. Los Arcos Mexican Restaurants, Inc., 313 F.R.D. 117, 123 (D. Colo. 2016). “Hybrid actions have troubled district courts across the country because of the inherent conflict between the opt-in requirement of FLSA collective actions and the opt-

out provisions of Rule 23(b)(3) class actions.” Id. In a Rule 23 class action, class members are bound by class judgment unless they affirmatively opt-out. See id. On the other hand, in an FLSA collective action, collective members must affirmatively opt- in to be bound by a judgment on behalf of the collective. See id. at 124. “Employees who do not opt-in are not similarly bound by the results of the litigation, including any settlement.” Id. In their Joint Motion, the parties ask the Court to approve the settlement of both the FLSA collective claim and the CWA class claim. Docket No. 74 at 1. “Although the opt-in requirement of FLSA collective actions conflicts with the opt-out provisions of Rule 23(b)(3) class actions, courts have permitted parties to enter into hybrid settlements to resolve both FLSA and state law claims.” German v. Holtzman Enters., Inc., No. 19-cv-03540-PAB-STV, 2023 WL 3585212, at *2 (D. Colo. May 22, 2023). Accordingly, courts have found it appropriate in hybrid actions to bind class members – who do not opt-out pursuant to Rule 23 – to the ultimate judgment, which includes the

release of FLSA claims. See id. at *10 (“The result of the application of res judicata is that individuals who do not opt out of the Rule 23 class, but do not opt in to the release of FLSA claims, are nevertheless bound by the settlement unless they show grounds for collateral attack on the judgment.”); Pliego, 313 F.R.D. at 132 (“This court is in agreement with courts which have found that normal res judicata principles apply in hybrid FLSA/Rule 23 collective/class actions, thus binding non opt-out Rule 23 Class Members who do not specifically opt-in to the release of FLSA claims to the ultimate judgment, unless such a claimant shows grounds for collateral attack on the judgment.”).

“Where parties seek settlement of a hybrid action, the settlement is evaluated on a combination of the factors required for preliminary approval of an FLSA action and those required for approval of a Rule 23 class settlement.” German, 2023 WL 3585212, at *2. Accordingly, the Court will determine, pursuant to Rule 23 and the FLSA, whether conditional certification of the proposed class is appropriate and whether the settlement agreement is fair and reasonable. III. PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT Approval of a class action settlement under Federal Rule of Civil Procedure 23 occurs in two stages. In the first stage, the court preliminarily certifies a settlement class, preliminarily approves the settlement agreement, and authorizes that notice be given to the class so that interested class members may object to the settlement’s fairness. In the second stage, after notice is given to the putative class, the court holds a fairness hearing at which it will address (1) any timely objections to the treatment of this litigation as a class action and (2) any objections to the fairness, reasonableness, or

adequacy of the settlement terms. Fed. R. Civ. P. 23(e)(2); see, e.g., McReynolds v. Richards-Cantave, 588 F.3d 790, 803 (2d Cir. 2009). “Preliminary approval of a class action settlement, in contrast to final approval, is at most a determination that there is . . . ‘probable cause’ to submit the proposal to class members and hold a full-scale hearing as to its fairness.” In re Crocs, Inc. Sec. Litig., No. 07-cv-02351-PAB-KLM, 2013 WL 4547404, at *3 (D. Colo. Aug. 28, 2013) (quoting Davis v. J.P. Morgan Chase & Co., 775 F. Supp. 2d 601, 607 (W.D.N.Y. 2011)). A proposed settlement of a class action should therefore be preliminarily approved where it “appears to be the product of serious, informed, non-collusive negotiations, has no

obvious deficiencies, and does not improperly grant preferential treatment to class representatives.” See In re Motor Fuel Temperature Sales Practices Litig., 286 F.R.D. 488, 492 (D. Kan. 2012) (internal quotation marks omitted). Although the standards for preliminary approval of a class action settlement are not as stringent as they are in the second stage, id., the standards used in the second stage inform the court’s preliminary inquiry. Therefore, it is appropriate to review those standards. District courts have broad discretion when deciding whether to certify a putative class. See Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 350 (2011); Shook v. Bd. of Cnty. Comm’rs of the Cnty. of El Paso, 386 F.3d 963, 967 (10th Cir. 2004). A district court may only certify a settlement class if it is “satisfied, after a rigorous analysis,” that the requirements of Rule 23 are met, and frequently, a district court’s “‘rigorous analysis’ will entail some overlap with the merits of the plaintiff’s underlying claim.” Dukes, 564 U.S. at 350–51; see also In re Initial Pub. Offerings Sec. Litig., 471 F.3d 24, 41 (2d Cir. 2006) (holding that “the obligation to make [Rule 23] determinations is not lessened by

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