Jackson v. Your Location Lubrication LLC
Filing
19
ORDER denying 18 motion to dismiss. On or before Wednesday, January 4, 2017, the parties may move for approval of an amended settlement agreement. Signed by Judge Roy B. Dalton, Jr. on 12/21/2016. (VMF)
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
ANTONIO JACKSON,
Plaintiff,
v.
Case No. 6:16-cv-1615-Orl-37TBS
YOUR LOCATION LUBRICATION LLC,
Defendant.
ORDER
This cause is before the Court on the parties’ Joint Motion for Approval of
Settlement and Dismissal of Action with Prejudice as to Defendant Your Location
Lubrication LLC and Incorporated Memorandum of Law (Doc. 18), filed December 20,
2016.
The parties to this action jointly request that the Court approve their settlement
agreement (Doc. 18-1 (“Settlement Agreement”)) as to Plaintiff’s claim for unpaid
overtime wages under the Fair Labor Standards Act (“FLSA”). (Doc. 18 (“Motion”).) Upon
consideration, the Court finds that the Motion is due to be denied and that the Settlement
Agreement is due to be rejected.
Congress enacted the FLSA to protect employees from “inequalities in bargaining
power between employers and employees.” See Lynn’s Food Stores, Inc. v. United States
ex rel. U.S. Dep’t of Labor, 679 F.2d 1350, 1352 (11th Cir. 1982). To further this
congressional purpose, the U.S. Court of Appeals for the Eleventh Circuit has placed
“limits on the ability of private parties to settle FLSA lawsuits.” See Nall v. Mal-Motels,
Inc., 723 F.3d 1304, 1307 (11th Cir. 2013); Lynn’s Food, 679 F.2d at 1352 (holding that
an employee’s rights under the FLSA “cannot be abridged by contract or otherwise
waived”).
Specifically, in FLSA actions, district courts must scrutinize any settlement “for
fairness” before entering a stipulated judgment. See Nall v. Mal-Motels, Inc., 723 F.3d
1304, 1306–07 (11th Cir. 2013); see also Wolff v. Royal Am. Mgmt., Inc.,
545 F. App’x 791, 793 (11th Cir. 2013). To do so, the Court must determine that any
settlement “is a fair and reasonable resolution of a bona fide dispute over FLSA
provisions.” Lynn’s Food, 679 F.2d at 1355. District courts are afforded discretion in
deciding whether to approve an FLSA settlement agreement. See Rodrigues v. CNP of
Sanctuary, LLC, 523 F. App’x 628, 629 (11th Cir. 2013). If the district court finds that the
settlement reflects a fair and reasonable compromise of the issues in dispute, it may
approve the settlement “in order to promote the policy of encouraging settlement in
litigation.” Lynn’s Food, 679 F.2d at 1354.
In exchange for monetary consideration, the instant Settlement Agreement
contains a general release pursuant to which Plaintiff agrees to release and forever
discharge Defendant “from any and all claims . . . of any nature whatsoever” that Plaintiff
has “arising out of or which have resulted or may result from Plaintiff’s employment.”
(Doc. 18-1, p. 1.) The inclusion of this general release language is fatal to the Motion. The
attempt to salvage the general nature of the release by limiting it to “claims arising out of
or which have resulted or may result from Plaintiff’s employment with Defendant” is
ineffective. This language would still arguably bar many types of claims outside the FLSA
context including, for example, claims under Title VII for discriminatory or retaliatory
conduct, among others.
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Importantly, the value of a full general release is typically incalculable and, thus,
cannot be saved by an arbitrary exchange of consideration. Moreover, because plaintiffs
can only compromise FLSA claims on the basis of a “dispute over FLSA provisions,”
concessions unrelated to the substance of FLSA claims have no place in FLSA
settlements. See Bonetti v. Embarq Mgmt. Co., 715 F. Supp. 2d 1222, 1228
(M.D. Fla. 2009). Indeed, a plaintiff’s FLSA claim—which is intended to remedy a
defendant’s violation of mandatory law—should not be used as leverage to procure a
general release of all possible claims. Cf. Lynn’s Food, 679 F.2d at 1352 (recognizing that
“[t]he FLSA was enacted for the purpose of protecting workers from substandard wages
and
oppressive
working
hours”);
see
also
Smith
v.
Lagassee,
Inc.,
No. 6:12-cv-676-Orl-36TBS, 2012 WL 5430961, at *1 (M.D. Fla. Nov. 7, 2012) (finding that
a general release “offends the principles of the FLSA.”). As such, the Motion is due to be
denied and the Settlement Agreement is due to be rejected.
Accordingly, it is hereby ORDERED AND ADJUDGED that:
1.
The parties’ Joint Motion for Approval of Settlement and Dismissal of Action
with Prejudice as to Defendant Your Location Lubrication LLC and
Incorporated Memorandum of Law (Doc. 18) is DENIED.
2.
The parties’ Settlement Agreement (Doc. 18-1) is REJECTED.
3.
On or before Wednesday, January 4, 2017, the parties may move for
approval of an amended settlement agreement consistent with the terms of
this Order.
DONE AND ORDERED in Chambers in Orlando, Florida, on December 21, 2016.
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Copies:
Counsel of Record
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