Reagh v. Giesen Management Associates, LLC

CourtDistrict Court, N.D. Ohio
DecidedOctober 13, 2023
Docket5:22-cv-00266
StatusUnknown

This text of Reagh v. Giesen Management Associates, LLC (Reagh v. Giesen Management Associates, LLC) 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
Reagh v. Giesen Management Associates, LLC, (N.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

COURTNEY REAGH, on behalf of herself ) CASE NO. 5:22-cv-266 and other similarly situated persons, ) ) ) PLAINTIFFS, ) JUDGE SARA LIOI ) vs. ) ) MEMORANDUM OPINION AND ) ORDER GIESEN MANAGEMENT ASSOCIATES, ) LLC, et al., ) ) DEFENDANTS. )

Before the Court is the parties’ joint motion for approval of settlement and dismissal of the case (Doc. No. 39 (Motion)), supported by the declarations of Ryan A. Winters (Doc. No. 39-5 (Winters Declaration)) and Mark W. Biggerman (Doc. No. 39-6 (Biggerman Declaration)). Because the Court finds that the settlement represents a fair resolution of plaintiffs’ claim under the Fair Labor Standards Act (“FLSA”), 29 U.S.C. §§ 201, et seq., the joint motion is granted, the settlement is approved, and the case is dismissed with prejudice. I. BACKGROUND On May 19, 2022, plaintiff Courtney Reagh (“Reagh”) filed an amended complaint, alleging that defendants Giesen Management Associates, LLC and David Giesen (jointly, “defendants”) violated the FLSA and Ohio Minimum Fair Wage Standards Act by failing to pay her, and potential plaintiffs to the collective action,1 all the overtime compensation to which they

1 In the months between the filing of the amended complaint and this order, the Sixth Circuit issued its opinion in Clark v. A&L Homecare and Training Ctr., LLC, 68 F.4th 1003, (6th Cir. 2023). The Sixth Circuit in Clark clarified that potential plaintiffs to an FLSA collective action differ from putative class members in important respects, and it cautioned against using the terms interchangeably. Clark, 68 F.4th at 1009–11. In her amended complaint, filed prior to the decision in Clark, Reagh alleges that she and members of a putative class were denied overtime in violation of were entitled. (Doc. No. 39, at 9.) Defendants denied liability or wrongdoing of any kind. (Id. at 10.) The parties initially engaged in extensive discovery, exchanged information about their respective positions, and engaged in informal settlement discussions. (Id. at 12.) The parties later engaged in formal mediation and exchanged employee time-logs and time-editing documents. (Id.

at 14.) After completing their review and analysis of the time-logs and related editing documents, the parties reached a settlement and filed the instant motion asking the Court to approve said settlement. (Id.) II. APPLICABLE LAW “Employees are guaranteed certain rights by the FLSA, and public policy requires that these rights not be compromised by settlement.” Crawford v. Lexington-Fayette Urban Cnty. Gov’t, No. 06-299-JBC, 2008 WL 4724499, at *2 (E.D. Ky. Oct. 23, 2008). “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.’” Id. (quoting 29 U.S.C. § 202) (further citation omitted). The provisions of the FLSA are mandatory and, except in two narrow circumstances, are generally not subject to bargaining, waiver, or modification by contract or settlement. Brooklyn Sav. Bank v. O’Neil, 324 U.S. 697, 706, 65 S. Ct. 895, 89 L. Ed. 1296 (1945); Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350, 1353 (11th Cir. 1982). The first exception involves FLSA claims that are supervised by the Secretary of Labor pursuant to 29 U.S.C. § 216(c). Lynn’s Foods,

Ohio Rev. Code § 4113.03. (Doc. No. 39, at 9. All page number references herein are to the consecutive page numbers applied to each individual document by the Court’s electronic docketing system.) As such, parties refer to both putative class members and to potential plaintiffs throughout the pleadings. The settlement, and this order, apply to both the potential plaintiffs to the collective action under the FLSA and to the putative class members. 679 F.2d at 1353. The second exception, applicable here, encompasses instances where a federal district court approves the settlement of a suit brought pursuant to § 216(b) of the FLSA. Id. In reviewing the settlement of a plaintiff’s FLSA claims, the district 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-1608, 2010 WL 2490989, at *5 (N.D. Ohio June 15, 2010) (quoting Collins v. Sanderson Farms, Inc., 568 F. Supp. 2d 714, 719 (E.D. La. 2000) (further citation omitted)). The existence of a bona fide dispute serves as a guarantee that the parties have not manipulated the settlement process to permit the employer to avoid its obligations under the FLSA. Id. (citing Crawford, 2008 WL 4724499, at *3). The Court should also consider the following factors: 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 *3 (citing Int’l Union, United Auto., Aerospace, and Agric. Implement Workers of Am. v. Gen. Motors Corp.,

497 F.3d 615, 631 (6th Cir. 2007)). Where the 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) (citing Blum v. Stenson, 465 U.S. 886, 893, 104 S. Ct. 1541, 79 L. Ed. 2d 891 (1984)). III. ANALYSIS At the outset, the Court finds that the divergent views of the facts and the law presented a bona fide dispute that, had the parties not reached settlement, would have necessitated resolution by the Court and/or a jury. The parties’ motion confirms the same. (Doc. No. 39, at 20.) In particular, the parties disagreed on whether the covered workers were entitled to overtime in any instance and, if so, the amount of missed overtime payments (Id.) The parties also disagreed about whether defendants were entitled to a good faith defense, and whether the defendants were joint employers for the purpose of an FLSA claim. (Id.) Having reviewed the terms of the settlement, the Court finds that the settlement represents a fair and reasonable resolution to the bona fide dispute. Further, the Court notes that the settlement

was the result of arms-length negotiations between parties that were represented by able counsel. (See id. at 21.) As such, the Court finds no risk of fraud or collusion. And, while the Court is not in a position to assess the likelihood of success on the merits, the Court finds that the other relevant factors weigh in favor of approving the settlement. With respect to the monetary awards, the settlement agreement provides that the plaintiffs will likely recover 100% of any alleged unpaid overtime during the relevant period, and 100% of liquidated damages for the same. (Doc. No.

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Related

Brooklyn Savings Bank v. O'Neil
324 U.S. 697 (Supreme Court, 1945)
Blum v. Stenson
465 U.S. 886 (Supreme Court, 1984)
Collins v. Sanderson Farms, Inc.
568 F. Supp. 2d 714 (E.D. Louisiana, 2008)
Reed v. Rhodes
179 F.3d 453 (Sixth Circuit, 1999)
Cullen v. Whitman Medical Corp.
197 F.R.D. 136 (E.D. Pennsylvania, 2000)
Brooke Clark v. A&L Homecare &Training Ctr.
68 F.4th 1003 (Sixth Circuit, 2023)

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Reagh v. Giesen Management Associates, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reagh-v-giesen-management-associates-llc-ohnd-2023.