Waltz v. Aveda Transportation and Energy Services, Inc., 4:16-cv-00469

Plaintiffs (Waltz and six others) are former Field Supervisor/Truck Push (FSTP) employees paid on a day-rate who sued under the FLSA for unpaid overtime and under Pennsylvania law for minimum-wage violations.
Plaintiffs contended they regularly worked over 40 hours/week and were misclassified as exempt from overtime.
Defendants asserted the FLSA "motor carrier" exemption applied (and that any driving under 10,000 lbs. was de minimis), and disputed hours worked and whether violations were willful (which affects the limitations period).
Court conditionally certified an FLSA collective; notice led to five additional opt-ins.
Parties conducted discovery and negotiated a settlement: $145,000 total common fund with $45,356.54 (31.28%) for attorneys’ fees; plaintiffs executed individual releases.
Court reviewed the settlement for fairness under FLSA settlement standards and granted approval, finding a bona fide dispute, reasonable attorney fees (cross-checked with lodestar), and that confidentiality/release terms did not frustrate the FLSA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether settlement resolves a bona fide FLSA dispute	Plaintiffs argued disputed facts (exemption, hours, willfulness) make settlement appropriate	Defendants maintained exemption and denied liability	Court found a bona fide dispute and approved settlement as fair and reasonable
Applicability of motor carrier exemption	Plaintiffs argued exemption did not apply (some driving <10,000 lbs.)	Defendants argued exemption applied and any small-vehicle driving was de minimis	Court did not decide merits; treated exemption dispute as a litigation risk supporting settlement
Proper limitations period (2 vs 3 years) — willfulness	Plaintiffs argued willful violations could extend to three-year period	Defendants disputed willfulness	Court recognized this unsettled factual/legal issue as a risk factor favoring settlement approval
Attorneys’ fees — percentage-of-recovery and lodestar cross-check	Plaintiffs sought $45,356.54 (31.28%) and provided lodestar showing higher figure	Defendants did not oppose	Court approved the 31.28% fee and cross-checked against lodestar ($84,288.50) yielding a .54 multiplier, finding the fee reasonable

Barrentine v. Arkansas–Best Freight System, 450 U.S. 728 (1981) (FLSA enacted to protect covered workers from substandard wages and hours)
Brooklyn Sav. Bank v. O’Neil, 324 U.S. 697 (1945) (FLSA protections cannot be waived by private contract)
Lynn’s Food Stores, Inc. v. United States Dep’t of Labor, 679 F.2d 1350 (11th Cir.) (1982) (court approval required for FLSA settlements)
Girsh v. Jepson, 521 F.2d 153 (3d Cir. 1975) (factors for assessing fairness of class/collective settlements)
In re Prudential Ins. Am. Sales Practice Litig., 148 F.3d 283 (3d Cir.) (lodestar cross-check for percentage-fee awards)
In re AT&T Corp. Sec. Litig., 455 F.3d 160 (3d Cir.) (lodestar multiplier methodology guidance)
Blum v. Stetson, 465 U.S. 886 (1984) (lodestar method: reasonable hours × reasonable rate)
D.A. Schulte, Inc. v. Gangi, 328 U.S. 108 (1946) (FLSA non-waiver principles reiterated)