Gaborik v. Taylor-Ray, 2:18-cv-00166

Plaintiff Patrick Gaborik worked at three truck rental locations managed by Defendant Katherine Taylor-Ray; he sometimes had the title "manager" and alleges he was misclassified as exempt and denied overtime.
Plaintiff’s demand letter sought $50,000 in unpaid wages and attorneys’ fees; Defendants denied liability and asserted affirmative defenses, including challenges to FLSA exemption and enterprise coverage.
Parties negotiated a global settlement: $6,000 to Plaintiff (split $3,000 unpaid overtime; $3,000 liquidated damages) plus $4,000 paid separately to Plaintiff’s counsel for fees and costs.
Magistrate Judge found a bona fide dispute over exempt status, enterprise coverage, and proper damage calculation (including potential application of the fluctuating workweek rule).
The Settlement Agreement contains a Full and Final Release limited to claims arising from the litigation or the Released Subject Matter; the Magistrate construed it as a specific—not general—waiver.
Magistrate recommends the district court approve the settlement as fair and reasonable, grant the second-filed joint motion, deny the first as moot, and dismiss the case with prejudice if adopted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Existence of a bona fide dispute under the FLSA	Gaborik says he was nonexempt and owed overtime for hours over 40	Defendants treat him as salaried exempt and dispute coverage, including enterprise/joint employer issues	Court: bona fide dispute exists; settlement review required under Lynn’s Food Stores
Fairness of monetary settlement amount	Gaborik initially demanded $50,000; agreed to $6,000 recovery in compromise	Defendants argue liability and damages are substantially uncertain; settlement reflects weakness of Plaintiff’s case	Court: $6,000 (and $3,000 liquidated) is persuasive, fair, and reasonable given disputed exemption and potential reduced damages under fluctuating workweek method
Attorneys’ fees arrangement	Plaintiff’s counsel agreed to separate fee negotiation after settling Plaintiff’s recovery	Defendants paid $4,000 to counsel separate from Plaintiff’s recovery; no fee tied to plaintiff’s amount	Court: fees negotiated separately; no evidence fees tainted plaintiff’s recovery; fee payment acceptable without separate reasonableness inquiry
Breadth of release	Gaborik limited release to claims "relating to" the litigation and Released Subject Matter	Defendants sought full release as part of global settlement	Court: release construed as specific to FLSA/litigation-related claims and not an impermissible general waiver; found fair and reasonable

Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (district court must approve FLSA settlements as fair and reasonable where bona fide dispute exists)
Bonetti v. Embarq Mgmt. Co., 715 F. Supp. 2d 1222 (M.D. Fla. 2009) (approving separate negotiation of plaintiff recovery and attorneys’ fees to avoid conflict of interest)
Moreno v. Regions Bank, 729 F. Supp. 2d 1346 (M.D. Fla. 2010) (cautioning against general releases in FLSA settlements)