Vazquez v. Montefiore Health System Inc.
7:24-cv-03811
S.D.N.Y.May 5, 2025Background
- Plaintiff, Angelique Vazquez, was employed by Montefiore Health System Inc. and Montefiore Mount Vernon Hospital from September 2019 to November 2022, performing clerical tasks and paid a fixed salary.
- Vazquez alleges she worked between 46.5-49 hours per week but was not paid overtime and was misclassified as an exempt employee under the FLSA and NYLL.
- The lawsuit asserts claims for unpaid overtime, liquidated and statutory damages, interest, attorneys’ fees, and equitable relief; it began as a putative collective action, but no additional plaintiffs joined, and no class was certified.
- The parties negotiated a $10,000 settlement (approx. $6,396.67 net to plaintiff after fees/costs), and sought court approval as required for FLSA cases under Cheeks v. Freeport Pancake House, Inc.
- The court found the financial terms reasonable but took issue with the settlement's release provision being overly broad (not limited to the claims at issue) and thus denied approval without prejudice.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Whether the settlement sum is fair and reasonable under FLSA and NYLL | Settlement is justified given litigation risks and uncertainty of facts | Settlement is fair due to factual and legal disputes on hours worked and exemption status | Settlement amount is reasonable based on risks, but release provision is too broad |
| Whether the release provision is permissible in wage/hour settlements | Agreed to a release covering wage/hour claims | Seeks broad release of liability, including all wage statutes | Court holds release is impermissibly broad; must be limited to claims at issue |
| Whether the non-disparagement clause is allowable | Permissible with a carve-out allowing truthful statements about the case | Clause allows for truthful statements; supports approval | Approved as properly limited |
| Whether requested attorneys’ fees are reasonable | Seeks 33.3% of settlement plus costs, supported by billing records | No objection; within normal range for FLSA cases | Court approves fee request as reasonable |
Key Cases Cited
- Cheeks v. Freeport Pancake House, Inc., 796 F.3d 199 (2d Cir. 2015) (FLSA settlements with prejudice require court or DOL approval)
- Wolinsky v. Scholastic Inc., 900 F. Supp. 2d 332 (S.D.N.Y. 2012) (factors for evaluating fairness of FLSA settlements)
- Nights of Cabiria, LLC, 96 F. Supp. 3d 170 (S.D.N.Y. 2015) (release provisions must be limited to claims at issue in wage/hour FLSA cases)