Seijas v. MMODAL Services, LTD., Inc.
5:17-cv-00218
M.D. Fla.Aug 9, 2017Background
- Plaintiff Michelle Seijas sued Mmodal Services, Ltd., Inc. under the FLSA (and asserted a related Florida Minimum Wage Act claim) for unpaid wages.
- Parties filed an amended joint motion asking the court to approve a stipulated settlement resolving the FLSA/FMWA claims.
- Proposed settlement: $17,500 total — $9,823.99 to Seijas for wage claims, $500 as extra consideration for a general release/covenants, and $7,676.01 for plaintiff’s attorneys’ fees and costs.
- Agreement also included mutual non-disparagement, a covenant not to seek reemployment, a neutral reference covenant, and a waiver of ADEA damages and certain claims, while preserving the right to pursue administrative proceedings (but waiving damages from them).
- Parties were represented by counsel and stated that fees were negotiated separately from plaintiff’s recovery; court reviewed reasonableness of fees but did not perform an in-depth lodestar analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the proposed FLSA settlement is a fair and reasonable compromise | Settlement is fair; resolves all sums due under FLSA and FMWA | Settlement is fair and reasonable as negotiated by counsel | Approved as a fair and reasonable compromise under Lynn’s Food scrutiny |
| Whether general release, non-disparagement, ADEA waiver, and no-reemployment clause render settlement unreasonable | Plaintiff received additional consideration ($500) and counsel protected her interests | Defendant asserts mutuality and separate consideration support these provisions | Court found these provisions reasonable given separate consideration and mutual terms |
| Whether attorney’s fees amount is reasonable | Plaintiff does not contest fees; fees were negotiated separately | Defendant agreed to fee amount; parties represent separation from plaintiff’s recovery | Court found $7,676.01 not patently unreasonable and approved it without in-depth analysis |
| Whether prior motion for approval is moot | N/A (amended motion supersedes prior) | N/A | Court terminated prior motion as moot |
Key Cases Cited
- Lynn’s Food Stores v. United States, 679 F.2d 1350 (11th Cir. 1982) (district court must scrutinize FLSA settlements and may approve reasonable compromises)
- Schulte, Inc. v. Gangi, 328 U.S. 108 (1946) (district court may enter stipulated judgments after scrutinizing fairness)