Lliguichuzhca v. Cinema 60, LLC, 2013 U.S. Dist. LEXIS 79543

Plaintiffs sued defendants for FLSA and NYLL violations.
Bench trial conducted March 4–5, 2013, resulting in liability findings for plaintiffs.
Damages were calculated, with plaintiffs’ counsel submitting a proposed total.
Settling parties sought court approval of a Full Release of All Claims.
Settlement proposed to pay $60,000 for dismissal with prejudice and broad releases.
Court requested and reviewed information on distribution and attorney’s fees; settlement approved and case dismissed with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FLSA settlement requires judicial approval.	Lliguiehuzhca contends approval is appropriate due to negotiated settlement.	Galanis/Man-ikes argue discretion on approval varies by jurisdiction.	Court proceeds with approval framework for fairness.
Whether the settlement is fair and reasonable under FLSA standards.	Settlement reflects compromise given collectability concerns.	Settlement should be preferred if it avoids overreach and preserves rights.	Court finds the settlement fair and reasonable.
Whether attorneys’ fees within the settlement are reasonable.	Counsel’s fees should not exceed fair share given results.	Fees should reflect negotiated outcome and efficiency.	Court approves fees as reasonable within the negotiated settlement.
Whether the settlement adequately protects plaintiffs’ interests given collectability issues.	Collectability concerns support settlement at a conservative amount.	Ability to collect against defendants is uncertain without settlement.	Court emphasizes collectability as a factor favoring approval.

Lynn's Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982) (settlement of wage claims requires fair and reasonable compromise of disputed issues)