Hutchinson v. Fast Pace Medical Clinic PLLC
3:22-cv-00511
| M.D. Tenn. | Oct 30, 2024Background
- Plaintiffs, on behalf of a class of hourly-paid current and former employees of Fast Pace Medical Clinic PLLC across several states, alleged wage and hour violations, including improper meal-break deductions and exclusion of bonuses from regular rate calculations.
- The plaintiffs negotiated a class and collective settlement totaling $1,850,000, with $595,877.48 (32%) designated for attorneys’ fees and $20,789.19 for litigation costs.
- Plaintiffs filed motions for final approval of the settlement, as well as for service awards, attorneys’ fees, and costs.
- Kathryn Farr, a class member, objected to the claims-made structure and the amount of fees and overall settlement.
- The district court held a fairness hearing, reviewed the settlement terms and objections, and assessed whether the settlement complied with applicable legal standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Claims-made structure | Consistent with hybrid FLSA/Rule 23 actions; valid | Appropriate opt-in/out process | Upheld; objection overruled |
| Amount/reasonableness of attorneys' fees | Fees reasonable given result and complexity; within norms | Fees reasonable and consistent with similar cases | Upheld requested fees; objection overruled |
| Appropriateness of class settlement | Arm’s-length, informed negotiations; fair to class | Settlement resolves bona fide dispute | Settlement found fair, reasonable, and adequate |
| Notice and procedural fairness | Notice adequate, class adequately represented | Notice procedures sufficient | Notice found proper, due process satisfied |
Key Cases Cited
- Boeing Co. v. Van Gemert, 444 U.S. 472 (1980) (establishes attorneys’ fees in common fund cases are based on the total fund, not just amounts claimed)
- Williams v. Vukovich, 720 F.2d 909 (6th Cir. 1983) (presumption of reasonableness for settlements resulting from arms-length negotiation; objector bears heavy burden)
- Moulton v. United States Steel Corp., 581 F.3d 344 (6th Cir. 2009) (percentage of common fund may be used to determine attorney fee awards in class settlements, even if unclaimed funds remain)