Ramos v. Steak N Shake, Inc.

CourtDistrict Court, N.D. Ohio
DecidedMarch 24, 2025
Docket1:21-cv-01212
StatusUnknown

This text of Ramos v. Steak N Shake, Inc. (Ramos v. Steak N Shake, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ramos v. Steak N Shake, Inc., (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

EMILY HARDING, on behalf of herself ) CASE NO. 1:21-cv-1212 and all others similarly situated, ) ) JUDGE BRIDGET MEEHAN BRENNAN Plaintiff, ) ) v. ) ) STEAK N SHAKE, INC., ) MEMORANDUM OPINION ) AND ORDER Defendant. )

Before the Court is the parties’ consent motion for approval of settlement. (Doc. 100.) Because the Court finds the settlement is a fair resolution of Plaintiffs’ claims under the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §§ 201, et seq., this motion is GRANTED, the settlement is APPROVED, and the case is DISMISSED with prejudice. I. BACKGROUND On June 21, 2021, Plaintiff Betsy Ramos filed a collective action lawsuit related to her work at Steak N Shake Inc. (“Steak N Shake” or “Defendant”). (Doc. 1.) Plaintiff Emily Harding was substituted as the Named Plaintiff. (Doc. 7.) Plaintiffs allege they were paid at an hourly rate less than the minimum wage in violation of the FLSA and the Ohio Minimum Fair Wage Standards Act. (See Doc. 15.) On February 11, 2022, the Court certified this case as a collective action. (Doc. 56.) Notices were mailed to potential collective members and 149 people, including Harding, opted into the case. (See Doc. 100 at 2034.)1 From July 2022 to February 2023, the parties engaged in written discovery and exchanged information about their respective positions. (See id. at 2033–

1 For ease and consistency, record citations are to the electronically stamped CM/ECF document and PageID# rather than any internal pagination. 34.) After discovery closed, Plaintiffs sought partial summary judgment on liability. (Doc. 83.) On August 15, 2024, Plaintiffs’ motion for partial summary judgment was granted in part and denied in part. (Doc. 91.) On November 12, 2024, the parties mediated before Magistrate Judge Jennifer Dowdell Armstrong. (November 12, 2024 Minutes of Proceedings.) The parties reached a settlement

agreement. (See November 25, 2024 Minutes of Proceedings; see also Doc. 100-1.) On February 7, 2024, the parties filed the instant motion for approval of the settlement agreement. The total settlement amount is $372,000. (Doc. 100 at 2035.) From the total settlement amount, $158,360.44 will be paid to Plaintiffs. (Id.) The settlement agreement further provides $141,360 in attorney’s fees, $37,279.56 in litigation costs, a $10,000 service award to Harding, and a maximum fee of $25,000 to a third-party administrator. (Id.) II. STANDARD OF REVIEW The “central purpose of the FLSA is to protect covered employees against labor conditions ‘detrimental to the maintenance of the minimum standard of living necessary for

health, efficiency, and general well-being of workers.’” Crawford v. Lexington-Fayette Urban Cnty. Gov’t, No. 06-299, 2008 WL 4724499, at *2, 2008 U.S. Dist. LEXIS 90070, at *11 (E.D. Ky. Oct. 23, 2009) (quoting 29 U.S.C. § 202). As a general rule, the FLSA’s provisions are not subject to bargaining, modification by contract, or settlement. See Brooklyn Sav. Bank v. O’Neil, 324 U.S. 697, 706–07 (1945) (holding policy considerations forbid waiver of rights created by the FLSA); Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350, 1353 (11th Cir. 1982) (FLSA provisions “are not subject to negotiation or bargaining between employers and employees”). There is an exception to this general rule when an employee brings a private action in a federal district court under 29 U.S.C. § 216(b) and presents the court with a proposed settlement. Id.; see also Pitty v. Conrad’s Laserwash Co., Inc., No. 5:23-cv-2034, 2023 WL 7166917, at *1, 2023 U.S. Dist. LEXIS 194639, at *2–3 (N.D. Ohio Oct. 31, 2023). Upon review of a settlement of FLSA claims, the court must “‘ensure that the parties are not, via settlement of [the] claims, negotiating around the clear FLSA requirements of

compensation for all hours worked, minimum wages, maximum hours, and overtime.’” Rotuna v. W. Customer Mgmt. Grp. LLC, No. 4:09-cv-16108, 2010 WL 2490989, at *5, 2010 U.S. Dist. LEXIS 58912, at *13 (N.D. Ohio June 15, 2010) (quoting Collins v. Sanderson Farms, Inc., 568 F.Supp. 2d 714, 719 (E.D. La. 2000)). The Court must “scrutinize the proposed settlement for fairness to determine whether the settlement is a ‘fair and reasonable resolution of a bona fide dispute over FLSA provisions.’” Pitty, 2023 WL 7166917, at *1, 2023 U.S. Dist. LEXIS 194639, at *3 (citing Bartlow v. Grand Crown Resorts of Pigeon Forge, No. 3:11-cv-400, 2012 WL 6707008, at *1, 2012 U.S. Dist, LEXIS 181808, at *4 (E.D. Tenn. Dec. 26, 2012)). Courts consider several factors including: the risk of fraud or collusion; the complexity, expense, and likely duration of the litigation; the amount of discovery completed; the likelihood

of success on the merits; and the public interest in settlement. Crawford, 2008 WL 4724499, at *2, 2008 U.S. Dist. LEXIS 90070, at *14 (citing Int’l Union, United Auto., Aerospace, & Agric. Implement Workers of Am. v. Gen. Motors Corp., 497 F.3d 615, 631 (6th Cir. 2007)). When a settlement agreement proposes an award of attorney’s fees, such fees must be reasonable. See generally Reed v. Rhodes, 179 F.3d 453, 471 (6th Cir. 1999). III. ANALYSIS This action presented a bona fide dispute. The parties set forth divergent views of the facts and the applicable law. The parties’ motion confirms as much. (Doc. 100 at 2037; see also Doc. 100-3 at 2094–95 (detailing disputes between the parties regarding liability and damages).) The terms of settlement resulted from arm’s length negotiations between the parties. There is no implication of fraud or collusion. See, e.g., Granada Invs., Inc. v. DWG Corp., 962 F.2d 1203, 1205 (6th Cir. 1992) (“Absent evidence of fraud or collusion, such settlements are not to be trifled with.”). (See also Doc. 100 at 2037.) Wage and hour class and collective actions are “inherently complex and time

consuming,” and this case is no exception. (Doc. 100 at 2037–38 (quoting Arledge v. Domino’s Pizza, Inc., No. 3:16-cv-386, 2018 WL 5023950, 2018 U.S. Dist. LEXIS 179474 (S.D. Ohio Oct. 17, 2018)). If the parties were to litigate this case further, they would incur additional expenses, including preparing for and completing a trial on the merits, which would involve complex and factually intensive questions on both liability and damages. (See id. at 2038.) The parties add that following a trial, either party would have appealed an adverse decision. (Id.) The parties engaged in extensive fact discovery, completing nine depositions and significant written discovery, and retained an expert. (See id.) As for success on the merits, settlement secures a substantial recovery for Plaintiffs. (Id. at 2038–39.)

Public policy supports approving the settlement. Rather than requiring the parties bear the risks of trial and a possible appeal, “the certainty and finality that comes with settlement also weighs in favor of approving the agreement.” Williams v. CH-HHC, Inv., No. 5:22-cv-1003, 2024 WL 1514587, at *2, 2024 U.S. Dist. LEXIS 63514, at *5 (N.D. Ohio Apr. 8, 2024). “Settlement is the preferred means of resolving litigation.” Crawford, 2008 WL 4724499, at * 9, 2008 U.S. Dist. LEXIS 90070, at *31.

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Related

Brooklyn Savings Bank v. O'Neil
324 U.S. 697 (Supreme Court, 1945)
Collins v. Sanderson Farms, Inc.
568 F. Supp. 2d 714 (E.D. Louisiana, 2008)
Reed v. Rhodes
179 F.3d 453 (Sixth Circuit, 1999)
Granada Investments, Inc. v. DWG Corp.
962 F.2d 1203 (Sixth Circuit, 1992)

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Bluebook (online)
Ramos v. Steak N Shake, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ramos-v-steak-n-shake-inc-ohnd-2025.