Kevin Berry, individually and on behalf of a putative class v. Western Carolina Pizza Ventures, LLC

District Court, W.D. North Carolina·Decided August 20, 2026·No. 3:25-cv-00961·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION CIVIL ACTION NO. 3:25-CV-00961-KDB-DCK

KEVIN BERRY, individually and on behalf of a putative class,

Plaintiff,

v. MEMORANDUM AND ORDER

WESTERN CAROLINA PIZZA VENTURES, LLC,

Defendant.

THIS MATTER is before the Court on the Parties’ Joint Motion for Settlement (Doc. No. 5). The Court has a fiduciary duty to carefully consider proposed class action settlements and has done so here, including hearing oral argument on the motion from the Parties’ counsel on August 18, 2026. Because the Court finds that the proposed settlement is neither fair nor adequate, the Court will DENY the motion. In particular, the Court concludes that (1) notice to the putative settlement class is not the best practicable means to give notice because it lacks notice by email and the inability of class members to make claims electronically, rendering the filing of claims far less likely (as no doubt intended by the Parties); (2) the purported “total amount” of the settlement is a collusive fiction driven by the Parties’ agreement on attorneys’ fees rather than a compromise of the actual value of disputed claims; (3) the Court cannot determine based on the available record if the amount offered to class members is an adequate payment for their alleged harm; and (4) the amount of attorneys’ fees is clearly excessive based on the lack of “success” achieved in the proposed settlement. By this ruling, the Court does not intend to discourage settlement; indeed, it encourages the Parties to settle their dispute if they are able to do so fairly, with (on the Plaintiff’s side) primary regard for the interests of the class members rather than their counsel. I. LEGAL STANDARD A class action may not be settled without approval of the Court. Fed. R. Civ. P. 23(e); see Williams v. PHH Mortg. Corp., No. 3:25-CV-00144-KDB-WCM, 2026 WL 1782163, at *1–2, *6

(W.D.N.C. June 22, 2026). Approval of a Federal Rule of Civil Procedure 23 class action settlement typically proceeds in two stages. At the first stage, the court examines the terms of the proposed settlement to determine whether it is within the range of possible approval, subject to further consideration at the final fairness hearing after interested parties have had an opportunity to object. Brent v. Advanced Med. Mgmt., LLC, 733 F. Supp. 3d 376, 380 (D. Md. 2024). Further, “[w]here a class-wide settlement is presented for approval prior to class certification, there must also be a preliminary determination that the proposed settlement class satisfies the prerequisites set forth in Fed. R. Civ. P. 23(a) and at least one of the subsections of Fed. R. Civ. P. 23(b).” Id. (citing Manual for Complex Litigation § 21.632 (4th ed. 2004) (“MCL”)). At the second stage,

after a final fairness hearing, “[i]f the proponents of the settlement [ ] satisf[y] their burden of showing that it is fair, adequate and reasonable, then the Court will approve the settlement.” Id. “The Rule 23 inquiry is certainly not meant to discourage settlement, but it is more than a rubber stamp[.]” Rodriguez v. Nat’l City Bank, 726 F.3d 372, 382 (3d Cir. 2013). “When the court reviews a proposed class-action settlement, it acts as a fiduciary for the class.” In re Lumber Liquidators Chinese-Manufactured Flooring Prods. Mktg., Sales Practices & Prods. Liab. Litig., 952 F.3d 471, 483-84 (4th Cir. 2020) (citing Sharp Farms v. Speaks, 917 F.3d 276, 293-94 (4th Cir. 2019). In this role, “the district court has a fiduciary responsibility to ensure that the settlement is fair and not a product of collusion, and that the class members' interests were represented adequately.” Sharp Farms, 917 F.3d at 294 (quoting Maywalt v. Parker & Parsley Petroleum Co., 67 F.3d 1072, 1078 (2d Cir. 1995) (cleaned up)). Further, the court must protect the class’s interests from parties and counsel overeager to settle (who may deny absent class members relief that they would otherwise receive) and frivolous objectors (who may impede or delay valuable compensation to others). 1988 Tr. for Allen Child. Dated 8/8/88 v. Banner Life Ins. Co., 28 F.4th

513, 521, 525 (4th Cir. 2022) Ultimately, the court must conclude that a proposed settlement is “fair, reasonable, and adequate.” Fed. R. Civ. P. 23(e)(2); 1988 Tr. for Allen, 28 F.4th at 520-21; MCL, § 21.632. Under Rule 23(e)(2), “[t]he fairness analysis is intended primarily to ensure that a ‘settlement is reached as a result of good-faith bargaining at arm's length, without collusion.’” Berry v. Schulman, 807 F.3d 600, 614 (4th Cir. 2015) (alteration omitted) (quoting In re Jiffy Lube Sec. Litig., 927 F.2d 155, 159 (4th Cir. 1991)). The Fourth Circuit has identified four factors for determining a settlement's fairness, which are: (1) the posture of the case at the time settlement was proposed; (2) the extent of discovery that had been conducted; (3) the circumstances

surrounding the negotiations; and (4) the experience of counsel in the area of class action litigation. 1988 Tr. for Allen, 28 F.4th at 527 (citing Lumber Liquidators, 952 F.3d at 484). With respect to adequacy, the Court considers the Jiffy Lube factors: (1) the relative strength of the case on the merits; (2) any difficulties of proof or strong defenses the plaintiff and class would likely encounter if the case were to go to trial; (3) the expected duration and expense of additional litigation; (4) the solvency of the defendants and the probability of recovery on a litigated judgment; and (5) and the degree of opposition to the proposed settlement. Jiffy Lube, 927 F.2d at 158; see also Lumber Liquidators, 952 F.3d at 484; Berry, 807 F.3d at 618 (“[T]he fact that only one of the approximately 200 million members of the ... Class objects ... is relevant to our decision [upholding the settlement as fair, reasonable, and adequate].”). The primary concern is the “protection of class members whose rights may not have been given adequate consideration during the settlement negotiations.” Jiffy Lube, 927 F.2d at 158. Approval of a class action settlement is committed to the “sound discretion of the district courts to appraise the reasonableness of particular class-action settlements on a case-by-case basis,

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Kevin Berry, individually and on behalf of a putative class v. Western Carolina Pizza Ventures, LLC, (W.D.N.C. 2026).

Kevin Berry, individually and on behalf of a putative class v. Western Carolina Pizza Ventures, LLC (Kevin Berry, individually and on behalf of a putative class v. Western Carolina Pizza Ventures, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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