8:20-cv-02978
M.D. Fla.Mar 31, 2022Background:
- Plaintiff Spaso Gavric, a former car salesman, sued Regal Automotive Group alleging unpaid compensation; claims included Count I (FLSA minimum-wage), Count II (Florida Minimum Wage Act), and state common-law commission/wage claims (Counts III–V).
- Three opt-in plaintiffs later joined but were directed to arbitrate; the case proceeded through discovery and mediation to an impasse.
- In March 2022 the parties informed the court they reached a settlement in principle and filed a Joint Motion to dismiss Count I (FLSA claim); they executed a written Agreement resolving Counts II–V but expressly excluded Count I from that Agreement.
- Parties contend the state minimum-wage settlement (Counts II–V) effectively resolves any FLSA claim, that little or no FLSA recovery remains, and therefore dismissal of Count I is appropriate.
- The court determined Lynn’s Food requires judicial scrutiny of FLSA settlements and found the unsubmitted Agreement likely "contaminates" the FLSA resolution (because Count II is also a minimum-wage claim); the court therefore deferred ruling and ordered the parties to submit the written settlement by April 8, 2022.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court may dismiss the FLSA claim based on the parties' joint motion | Gavric seeks dismissal because FLSA damages are small and risks of litigation outweigh benefits | Regal concurs; both say state settlement de facto precludes FLSA recovery and no FLSA funds are allocated | Court deferred ruling; required settlement submission for review under Lynn's Food before dismissing Count I |
| Whether the parties may withhold the non-FLSA settlement from the court | Parties contend non-FLSA settlement need not be filed and does not require court approval | Same: confidentiality and separate treatment warranted | Court held non-FLSA agreement may not be kept secret if it affects FLSA claim; directed submission because terms appear to "contaminate" FLSA resolution |
| Whether absence of funds allocated to the FLSA claim obviates judicial scrutiny | Plaintiff argues no compromise exists because no money was paid for Count I | Defendant likewise argues no monies will be owed under FLSA given state settlement | Court rejected that position; required information and review to prevent an end-run around FLSA protections |
Key Cases Cited
- Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (district courts must scrutinize and approve FLSA settlements)
- Goldsby v. Renosol Seating, LLC, 294 F.R.D. 649 (S.D. Ala. 2013) (courts may require additional information about plaintiff’s decision to dismiss FLSA claims)
