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Felts v. Ark Potomac Corporation
Civil Action No. 2021-0656
| D.D.C. | Dec 21, 2021
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Background

  • Plaintiffs (including Rebecca Felts) sued Ark Potomac d/b/a Sequoia under the FLSA and DCMWA for unpaid minimum wages and overtime.
  • Parties negotiated a settlement and moved for court approval; the agreement provided 100% of backpay for a three-year period plus liquidated damages structured as a 10% add-on (not full FLSA liquidated damages) and a discounted attorneys’ fee recovery.
  • Felts contacted the court ex parte expressing objections, later claimed she signed reluctantly after counsel threatened to withdraw, and alleged calculation errors in her settlement amount.
  • Plaintiffs’ counsel moved to withdraw due to irreconcilable differences/conflict of interest; the Court granted withdrawal and ordered Felts to either seek new counsel or set forth objections in writing; Felts proceeded pro se and filed objections.
  • The Court reviewed the settlement for a bona fide dispute and overall fairness, considered counsels’ negotiations, discovery, and the settlement formula, and evaluated the reasonableness of attorneys’ fees and expenses.
  • The Court approved the settlement over Felts’s objections, concluding the deal was the product of arm’s-length bargaining, reasonably reflected the parties’ relative positions, and contained reasonable fee arrangements.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the settlement resolves a bona fide dispute Felts did not dispute the existence of a dispute but contested fairness and calculations Parties agreed a bona fide dispute existed between plaintiffs and defendant Court: Settlement resolves a bona fide dispute; review proceeds
Whether the settlement is fair and reasonable Felts argued she signed reluctantly, liquidated damages undervalued, and wage data miscalculated Parties argued arm's-length bargaining, informal discovery informed valuation, and settlement approximates plaintiffs’ recovery Court: Settlement is fair — negotiated in good faith, reasonable relative to strengths/weaknesses, close to plaintiffs’ asserted damages
Whether counsel’s withdrawal was proper Felts opposed withdrawal and contested counsel’s conduct Plaintiffs’ counsel asserted irreconcilable differences and conflict of interest Court: Withdrawal was appropriate under Local Civil Rule due to conflict/irreconcilable differences
Whether attorneys’ fees and expenses are reasonable Felts implicitly challenged the deal but did not present a counter on fees Plaintiffs argued hours and lodestar were reasonable and fees in settlement were a substantial discount Court: Fees and expenses are reasonable; settlement limits review to monetary compromise terms

Key Cases Cited

  • Stephens v. Farmers Restaurant Grp., 329 F.R.D. 476 (D.D.C. 2019) (describing standards for court review of FLSA settlements)
  • Carrillo v. Dandan Inc., 51 F. Supp. 3d 124 (D.D.C. 2014) (presumption of fairness for settlements and factors to evaluate employer overreaching)
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Case Details

Case Name: Felts v. Ark Potomac Corporation
Court Name: District Court, District of Columbia
Date Published: Dec 21, 2021
Docket Number: Civil Action No. 2021-0656
Court Abbreviation: D.D.C.