Johnson v. Bodi Services, LLC, 5:17-cv-00123

Plaintiff Cody Johnson sued Bodi Services, LLC and individual Hardings under the FLSA alleging unpaid overtime for manual labor in oil and gas services.
Defendants did not appear; parties reached a confidential settlement and Plaintiff moved to approve attorneys’ fees and expenses.
Magistrate judge ordered counsel to file sealed billing details; counsel reported 10 hours total (6 by Alexander, 3 by Braddy, 1 paralegal) and $655 in expenses.
Counsel sought $2,000 in fees (below their calculated lodestar of at least $2,851.10), citing reasonableness and facilitation of settlement.
Court evaluated: (1) whether the FLSA settlement is a fair, reasonable resolution of a bona fide dispute (necessary because statutory wage claims require court or DOL supervision), and (2) whether the requested fee is reasonable under the lodestar approach.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FLSA settlement should be approved	Johnson contends the settlement fairly and reasonably resolves a bona fide FLSA dispute	Defendants did not appear or oppose; no contrary position in record	Approved: settlement is a fair and reasonable compromise over bona fide disputes and may be judicially supervised under Lynn’s Food/Bodle framework
Whether requested attorneys’ fees are reasonable	Johnson sought $2,000 (below counsel’s lodestar estimate) as reasonable and to facilitate resolution	No opposition from defendants; court independently evaluates lodestar and reasonableness	Awarded $2,000: court calculated a minimum lodestar of $2,851.10 but approved the lower agreed amount as reasonable
Proper method for fee calculation	Johnson relied on lodestar (hours × reasonable rate) and cited prior cases and State Bar survey to support rates	No opposition presented; court scrutinized market rates and reduced reliance on claimed percentiles lacking record support	Used lodestar method, adjusted by assessing local market data; court adopted conservative aggregate rate for attorneys and kept paralegal rate unchanged
Whether further adjustment under Johnson factors required	Johnson argued fee request reasonable and modest	No opposing argument; court considered that an award below lodestar obviates need for full Johnson-factor analysis	No Johnson-factor adjustment necessary because requested fee is well below calculated lodestar

Brooklyn Sav. Bank v. O’Neil, 324 U.S. 697 (establishes that statutory wage claims cannot be waived by agreement)
Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (court-supervised settlements permissible when resolving bona fide FLSA disputes)
Bodle v. TXL Mortg. Corp., 788 F.3d 159 (5th Cir. 2015) (reiterates need for court or DOL supervision of FLSA settlements)
Saizan v. Delta Concrete Prods. Co., Inc., 448 F.3d 795 (5th Cir. 2006) (endorses lodestar method for fee awards)
Hensley v. Eckerhart, 461 U.S. 424 (lodestar burden and standards for fee requests)
Cox v. Brookshire Grocery Co., 919 F.2d 354 (5th Cir. 1990) (fees need not be proportional to recovery)
Watkins v. Fordice, 7 F.3d 453 (5th Cir. 1993) (lodestar may be adjusted under Johnson factors)
Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974) (set of factors for adjusting lodestar)
Thomas v. Arn, 474 U.S. 140 (standard for objections to magistrate judges’ reports)
Battle v. United States Parole Comm’n, 834 F.2d 419 (5th Cir. 1987) (limitations on review of frivolous or general objections)