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Bozeman v. The City of Opp, Alabama
2:14-cv-01042
M.D. Ala.
Jun 25, 2015
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Background

  • Plaintiff Bozeman; defendants City of Opp, Opp Utilities Department, and Utilities Board of the City of Opp allegedly violated the FLSA and Equal Pay Act by underpaying wages.
  • The parties proposed a settlement of Bozeman's back-wage claims under 29 U.S.C. §216(b) and submitted it to the district court for approval.
  • The court conducted an on-the-record conference to review the proposed settlement.
  • FLSA provisions are generally non-waivable, with two narrow exceptions: Secretary-supervised back wages under §216(c) and private suits settled with court approval under §216(b).
  • The court found bona fide disputes over FLSA provisions, including whether Bozeman and a male comparator performed equal work under equal conditions.
  • Bozeman will receive $25,000, and her counsel will be paid $12,500 under the contingency-fee agreement, covering costs; she releases claims up to the settlement date; a judgment will be entered.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Is the FLSA private-action settlement fair and reasonable? Bozeman asserts a reasonable compromise reflecting disputed issues. Opposes arguments but supports settlement as an appropriate resolution. Settlement approved as fair and reasonable.
Does the settlement comply with FLSA waiver rules and procedures? Settlement follows the private-action pathway with court review under §216(b). Settlement correctly avoids improper waivers and adheres to statutory framework. Approved under the §216(b) framework as a fair resolution.
Were there bona fide disputes under the FLSA provisions warranting settlement approval? Disputes exist over whether Bozeman and comparator performed equal work under equal conditions. Disputes exist and require resolution via settlement. Court found bona fide disputes and approved the settlement.

Key Cases Cited

  • Brooklyn Savings Bank v. O’Neil, 324 U.S. 697 (Supreme Court 1945) (FLSA rights generally non-waivable; limited exceptions apply)
  • Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (private settlements may be approved when adversarial context exists and terms are fair)
  • Stalnaker v. Novar Corp., 293 F. Supp. 2d 1260 (M.D. Ala. 2003) (court may approve settlements ensuring protections under wage laws)
Read the full case

Case Details

Case Name: Bozeman v. The City of Opp, Alabama
Court Name: District Court, M.D. Alabama
Date Published: Jun 25, 2015
Docket Number: 2:14-cv-01042
Court Abbreviation: M.D. Ala.