Cuttic v. Crozer-Chester Medical Center
2012 U.S. Dist. LEXIS 86486
| E.D. Pa. | 2012Background
- Plaintiff filed a putative FLSA collective action against CCMC and related entities; all other defendants were dismissed, leaving CCMC as the sole defendant.
- Plaintiff alleged CCMC failed to pay overtime under the FLSA, 29 U.S.C. § 207(a).
- The court previously concluded Plaintiff was not exempt and was entitled to overtime at summary judgment.
- On June 4, 2012, the parties notified the court of a settlement and sought in camera review of the confidential settlement; the court’s review addressed whether to seal the agreement or file it publicly.
- The court scheduled a July 2, 2012 deadline for the parties to withdraw or request a public hearing on fairness; oral argument occurred June 12, 2012.
- The court denied in camera review, relying on the public-access presumption for FLSA settlements and lack of compelling justification for sealing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FLSA settlement should be reviewed in camera or sealed. | The parties argued confidentiality; public access should be overridden. | Confidentiality was a material term and necessary to avoid public backlash. | Denied in camera review; public access applies; no sufficient justification to seal. |
Key Cases Cited
- Littlejohn v. Bic Corp., 851 F.2d 673 (3d Cir. 1988) (right of access to judicial records is beyond dispute)
- Bank of Am. Nat’l Trust & Sav. Ass’n v. Hotel Rittenhouse Assocs., 800 F.2d 339 (3d Cir. 1986) (strong presumption of access for judicial records, including settlements)
- Pansy v. Borough of Stroudsburg, 23 F.3d 772 (3d Cir.1994) (settlement agreements filed with or enforced by a court are judicial records)
- Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (court can approve a compromise if fair and reasonable; involves judicial interpretation)
- Enprotech Corp. v. Renda, 983 F.2d 17 (3d Cir. 1993) (judicial interpretation may render settlement documents public)
- United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995) (distinguishes judicial documents and public access when relevant to judicial function)