West v. Emeritus Corporation
3:15-cv-00437
| M.D. Tenn. | Jul 5, 2017Background
- Plaintiff Cara L. West sued under the Fair Labor Standards Act (FLSA), alleging she was non‑exempt and unpaid for overtime; Defendant Emeritus Corporation contended she was an exempt executive.
- No collective‑action certification was sought; this was an individual action approaching trial.
- Parties completed full factual discovery (payroll records produced; plaintiff deposed) and engaged in arms‑length settlement talks.
- The parties filed a joint motion to approve a settlement requiring Defendant to pay $55,000: $8,993.69 to Plaintiff (wages) and $46,006.31 for attorney’s fees and costs; Plaintiff would dismiss and release most claims.
- The court reviewed the settlement under FLSA settlement standards and found it public, nonconfidential, and a reasonable compromise over disputed FLSA coverage.
- Court approved the settlement, finding it fair, reasonable, and adequate, and dismissed the case with prejudice (parties to bear their own fees except as provided in the agreement).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FLSA claim merits approval of a private settlement | Settlement provides substantially all alleged unpaid overtime and certainty | Plaintiff was actually an exempt executive; continued litigation poses risk | Court approved settlement as fair, reasonable, and adequate |
| Whether settlement resulted from fraud or collusion | Negotiations were arms‑length through counsel | N/A (Defendant participated in joint motion) | Court found little to no risk of fraud or collusion |
| Whether attorney’s fees in settlement are reasonable under FLSA | Fees justified by work and FLSA fee‑shifting policy despite modest plaintiff recovery | N/A (no objection recorded) | Court held $46,006.31 reasonable given FLSA norms and stage of case |
| Whether public interest supports approval | Public interest favors settlement of bona fide FLSA disputes and transparency | N/A | Court found approval served public interest (settlement public, reasonable compromise) |
Key Cases Cited
- UAW v. Gen. Motors Corp., 497 F.3d 615 (6th Cir.) (factors to evaluate fairness of class/collective settlements)
- Granada Invs., Inc. v. DWG Corp., 962 F.2d 1203 (6th Cir.) (court may weigh only relevant settlement factors)
- Fegley v. Higgins, 19 F.3d 1126 (6th Cir.) (FLSA fee awards should not be overly tied to plaintiff's recovery)
- Dean v. F.P. Allegra Concrete Const. Corp., [citation="622 F. App'x 557"] (6th Cir.) (criticizing disproportionate fee awards where plaintiff recovery was minimal)