Vikram v. First Student Management, LLC, 4:17-cv-04656

Plaintiff Bhanu Vikram, a San Francisco bus driver, brought a putative class action against First Student Management alleging (1) unpaid pre-shift time at the bus yard and (2) failure to include non-discretionary "lift/comm" incentive pay in the regular rate for overtime calculation.
The parties mediated, agreed to settle only the lift/comm overtime-related claims for drivers at the San Francisco location (class period July 6, 2013–June 15, 2018), and proposed a Gross Settlement Amount of $435,000 (including $10,000 PAGA penalties).
Net Settlement Amount after fees, costs, PAGA allocation, and administration was $290,087.50 to be allocated pro rata by workweeks (with a 2.0 multiplier for former employees for waiting-time exposure).
The settlement releases only claims related to failure to pay overtime on lift pay; other claims (e.g., pre-shift uncompensated time) were dismissed without prejudice.
Court preliminarily approved notice; 335 class members were mailed notice, no opt-outs, three procedural objections regarding workweek calculations were resolved, and no governmental objections were filed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Final approval: is the settlement fair, reasonable, adequate?	Settlement reasonably compensates class for lift/comm overtime risk and was result of arms-length mediation.	Settlement reflects resolution of disputed liability and class certification risks.	Granted: Court found Churchill factors favor approval; no Bluetooth collusion signs.
Attorney's fees: is 25% of common fund reasonable?	Requests 25% ($108,750) as benchmark percentage; litigation was risky and required expert work.	No opposition.	Granted: 25% benchmark reasonable; lodestar cross-check produced a sub-multiplier supporting the award.
Costs: are requested litigation costs reasonable?	Seeks $10,000 (actual costs $12,966.25).	No opposition.	Granted: Court awards $10,000 as reasonable.
Service award: is $10,000 for named plaintiff appropriate?	Asks $10,000 for ~100 hours and release execution.	Defendant did not oppose, but court assesses reasonableness.	Denied in part: reduced to $5,000 as more consistent with district practice and plaintiff's involvement.

Churchill Village, LLC v. General Electric, 361 F.3d 566 (9th Cir.) (factors for evaluating fairness of class settlements)
In re Bluetooth Headset Products Liability Litigation, 654 F.3d 935 (9th Cir.) (heightened scrutiny for potential collusion in fee arrangements)
Vizcaino v. Microsoft Corp., 290 F.3d 1043 (9th Cir.) (lodestar cross-check and multiplier guidance)
Rodriguez v. West Publishing Corp., 563 F.3d 948 (9th Cir.) (standards and purposes for service/incentive awards)
Maldonado v. Epsilon Plastics, Inc., 22 Cal. App. 5th 1308 (Cal. Ct. App.) (wage-statement penalty requires showing of injury)
Van Vranken v. Atlantic Richfield Co., 901 F. Supp. 294 (N.D. Cal.) (context for larger incentive awards in extraordinary representative involvement)