Herrera v. R+L Freight Services, LLC, 2:16-cv-00795

Plaintiffs Lynn Herrera and Margaret Raber (and six opt-in plaintiffs) sued Defendants (Paramount Transportation Logistics Services, R&L Carriers, AFC Worldwide Express d/b/a R&L Global Logistics) under the FLSA, alleging misclassification as exempt and unpaid overtime.
Plaintiffs claimed routine overtime worked and sought back wages and liquidated damages; defendants disputed exemption, employer status, overtime hours, statute of limitations, and entitlement to liquidated damages.
The parties reached a settlement: defendants to pay each named plaintiff specified amounts equal to 80% of claimed damages (including liquidated damages), with allocation saying 70% for FLSA release and 10% for a general release.
Defendants separately agreed to pay $41,623.04 in attorneys’ fees and costs, purportedly negotiated independently of plaintiffs’ recovery.
The parties filed a Joint Motion for Approval of Settlement and submitted individual Receipt and Release forms that included a clause retaining the Middle District of Florida’s jurisdiction to enforce the release.
The Magistrate Judge recommended approval of the settlement as a fair and reasonable compromise under Lynn’s Food, but recommended excising the parties’ inclusion of Court retention of jurisdiction because the parties failed to request or justify it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FLSA claim settlement is a fair and reasonable resolution of a bona fide dispute	Settlement reflects compromise of disputed FLSA coverage, hours, damages and is fair	Settlement resolves bona fide disputes; fees negotiated separately so no conflict	Approved as fair and reasonable under Lynn’s Food framework
Whether attorney’s fees must be separately scrutinized for reasonableness	Plaintiffs rely on counsel’s negotiated fee and disclosure	Defendants note fees agreed without regard to plaintiffs’ recovery	Court accepts separate agreement; no separate fee reasonableness inquiry required per Bonetti unless apparent conflict
Whether general releases in receipts are supported by adequate consideration	Plaintiffs assert 10% of alleged damages allocated to general release constitutes adequate consideration	Defendants contend allocation suffices and releases were disclosed	Court finds 10% allocation appears fair and reasonable for general releases
Whether the Court should retain jurisdiction to enforce the settlement	Plaintiffs included language requesting retained jurisdiction in releases but did not separately move for it or justify it	Defendants included retention language in releases without briefing; no independent jurisdictional basis offered	Court recommends approving settlement but declines to retain post-judgment jurisdiction absent request or justification

Lynn’s Food Store, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (court must determine FLSA settlements are fair and reasonable compromises of bona fide disputes)
Bonetti v. Embarq Management Company, 715 F. Supp. 2d 1222 (M.D. Fla. 2009) (district court may accept separately negotiated attorneys’ fees without separate reasonableness inquiry absent evidence of conflict)