Iannone v. AutoZone Inc, 2:19-cv-02779

Plaintiffs, participants in the AutoZone, Inc. 401(k) Plan, alleged that defendants, including AutoZone and Northern Trust (investment advisor), breached their fiduciary duties under ERISA by mismanaging the Plan.
The action was brought as a class action on behalf of all Plan participants as of November 11, 2013, who invested in certain funds, with specified exclusions (primarily AutoZone insiders and related parties).
After extensive litigation, including substantial discovery and motions practice, Plaintiffs and Northern Trust announced a settlement on the first day of trial.
The settlement provides for a $2.5 million payment by Northern Trust to the class, subject to court approval.
The court also considered and preliminarily approved a bar order preventing Northern Trust and AutoZone from seeking contribution or indemnification against each other related to this action.
The court must now consider whether the settlement meets preliminary approval standards under Rule 23 and whether class notice and procedures are adequate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the class settlement should be preliminarily approved as fair, reasonable, and adequate	Settlement is fair; reached after arm's length negotiation and avoids further costly litigation	No opposition; supports approval with noted cooperation needed on data	Preliminarily approved
Whether the method of allocating and distributing settlement funds is equitable	Flat per capita distribution is equitable given low dollar amount and administrative burden	No opposition; raises logistical points about data availability	Approved; flat distribution accepted as reasonable
Whether proposed attorney’s fee and incentive awards are reasonable	Fee and award are reasonable given complexity and duration	No challenge; fees within market range	Fee method and amount preliminarily approved
Whether a bar order precluding contribution/indemnification between settling parties is appropriate	Needed for finality and as a condition of settlement	No opposition; supports bar order	Bar order preliminarily approved

UAW v. GMC, 497 F.3d 615 (6th Cir. 2007) (factors relevant to preliminary approval of a class settlement)
Rawlings v. Prudential-Bache Props., 9 F.3d 513 (6th Cir. 1993) (discussing the lodestar and percentage of fund method for attorney's fees)
In re Dry Max Pampers Litig., 724 F.3d 713 (6th Cir. 2013) (incentive awards for plaintiffs in class actions can present fairness concerns)
Poplar Creek Dev. v. Chesapeake Appalachia, L.L.C., 636 F.3d 235 (6th Cir. 2011) (likelihood of success is relevant to settlement approval)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (standards for award of attorney's fees)
Doe v. Déjà Vu Consulting, Inc., 925 F.3d 886 (6th Cir. 2019) (public interest in settlement of class actions)
In re Greektown Holdings, LLC, 728 F.3d 567 (6th Cir. 2013) (bar orders in federal litigation and limitation to contribution or indemnity claims)